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Performance Audit & Sunset Review Arizona State Schools for the Deaf and the Blind

Arizona State Schools for the Deaf and the Blind

A REPORT
TO THE
ARIZONA LEGISLATURE
Debra K. Davenport
Auditor General
Performance Audit and Sunset Review
Arizona State
Schools for the
Deaf and the Blind
Performance Audit Division
September • 2012
REPORT NO. 12-05
The Auditor General is appointed by the Joint Legislative Audit Committee, a bipartisan committee composed of five senators and five
representatives. Her mission is to provide independent and impartial information and specific recommendations to improve the opera-tions
of state and local government entities. To this end, she provides financial audits and accounting services to the State and political
subdivisions, investigates possible misuse of public monies, and conducts performance audits of school districts, state agencies, and
the programs they administer.
The Joint Legislative Audit Committee
Audit Staff
Copies of the Auditor General’s reports are free.
You may request them by contacting us at:
Office of the Auditor General
2910 N. 44th Street, Suite 410 • Phoenix, AZ 85018 • (602) 553-0333
Additionally, many of our reports can be found in electronic format at:
www.azauditor.gov
Dale Chapman, Director
Shan Hays, Manager and Contact Person
Kori Minckler, Team Leader
Jay Rasband
Beth Rensvold
Richie Rinaldi
Representative Carl Seel, Chair
Representative Tom Chabin
Representative Justin Olson
Representative David Stevens
Representative Anna Tovar
Representative Andy Tobin (ex officio)
Senator Rick Murphy, Vice Chair
Senator Andy Biggs
Senator Rich Crandall
Senator Linda Lopez
Senator David Lujan
Senator Steve Pierce (ex officio)
ASDB uses standardized tests
to assess student progress—
These tests include the state-wide
Arizona’s Instrument to Measure
Standards (AIMS) test as well as
another test similar to the AIMS
called Measures of Academic
Progress (MAP).
Most ASDB students did not
meet standards on AIMS—
ASDB students generally scored
lower on AIMS than did Arizona
students as a whole. Although
some ASDB students passed and
even exceeded standards on the
spring 2011 AIMS, most did not.
MAP results showed students
made some progress but still
testing well below grade level—
ASDB students’ MAP test scores
showed that they start at a much
lower level than national norms. Although
limited growth occurred after 5th and 6th
grades and continued into high school, it
was not sufficient to bring students’ scores
within reach of national norms. For
example, by the 11th grade, ASDB
students scored the same as the average
3rd-grade student would in reading and
scored slightly below the average
4th-grade student in math.
Standardized test scores are limited
indicators of program success—Sensory-impaired
students may have difficulty
taking standardized tests because of
natural disadvantages these students may
face in taking these tests. In addition, there
is little comparative information about
scores attained by similar students in other
Arizona schools or other states’ schools.
ASDB uses common practices, but can
strengthen its practices—To help ensure
success in educating its students, ASDB
2012
September • Report No. 12-05
Arizona State
Schools for the
Deaf and the Blind
Our Conclusion
The Arizona State Schools
for the Deaf and the Blind
(ASDB) serves children and
students from birth through
21 years of age who have
sensory impairments such
as deafness and blindness.
As of April 2012, ASDB had
2,240 students who either
attended one of its three
on-campus schools,
participated in its birth to
age three or preschool
programs, or received ASDB
services at their local
schools. ASDB can do more
to promote student success
by ensuring that children
with sensory impairments
receive services early in their
lives, increasing students’
access to highly qualified
teachers, and researching
and addressing differences
in students’ test scores.
ASDB should also ensure its
regional cooperative
program, which serves
students at their local
schools, more fully recovers
its costs. It should also
strengthen oversight and
management of the
program. Finally, ASDB
needs to address critical
information technology
weaknesses.
REPORT
HIGHLIGHTS
PERFORMANCE AUDIT
ASDB can do more to promote student success
follows commonly used practices,
including using technology to help
students learn. In addition, ASDB groups
students according to their academic
ability rather than age. However, ASDB
can strengthen the following practices:
• Early Intervention—Early interven-tion
services are a critical element in
a student’s success. ASDB provides
early intervention services through a
program called Arizona Early Interven-tion
Program. ASDB has identified
areas where it can do more to improve
this program such as coordinating with
the other agencies involved in the pro-gram,
better organizing and training
staff, and reaching out to families with
sensory-impaired infants and children.
• Highly qualified teachers—Federal
law requires that disabled students
be taught by teachers who are highly
qualified in special education and in
core academic subjects. According
Spring 2011 AIMS Test Results for ASDB Students
and State-wide Students
0
10
20
30
40
50
60
70
Falls Far Below Approaches Meets Exceeds Percent of Students
Reading
ASDB
State-wide
0
10
20
30
40
50
60
Falls Far Below Approaches Meets Exceeds
Percent of Students
Math
ASDB
State-wide
Arizona State
Schools for the
Deaf and the Blind
REPORT
HIGHLIGHTS
PERFORMANCE AUDIT
September 2012 • Report No. 12-05
A copy of the full report is available at:
www.azauditor.gov
Contact person:
Shan Hays (602) 553-0333
to an Arizona Department of Education report,
about 90 percent of ASDB teachers were highly
qualified during the 2011-2012 school year.
According to ASDB officials, it is difficult to hire
and retain highly qualified teachers for many
reasons, including lack of competitive pay and
the challenges of obtaining the required certifi-cations.
ASDB is working with the University of
Arizona and the Arizona Department of Educa-tion
to increase the pool of qualified teachers.
• Studying differences in test scores—Federal
law requires that all public schools work to nar-row
achievements gaps in their states. Study-ing
differences in AIMS passing rates across
the various ASDB locations may help improve
ASDB’s student achievement.
Recommendations—ASDB should:
• Improve its early intervention program to ensure
that children receive needed services.
• Increase students’ access to highly qualified
teachers.
• Study differences in test scores and implement
potential solutions to improve student achieve-ment.
ASDB provides services at local school districts
through its regional cooperative program—ASDB
established a regional cooperative program in 1988
to help local school districts serve sensory impaired
students. There are five regional cooperatives, and
each has a staff of teachers, interpreters, and other
specialists. About one-half of state school districts
participate in the program.
Funding comes from various sources—Funding
for the regional cooperatives comes from special
education vouchers through the Arizona
Department of Education for assessments,
counseling, and direct teaching services; from the
State General Fund for program administrative
costs; and from school district membership fees to
screen children and train school staff.
ASDB should examine fees—Each regional
cooperative has established its own membership
fees it charges to school districts. Districts also pay
ASDB for direct educational services provided to
their sensory impaired students. ASDB does not
have policies for determining appropriate
membership and other fees. Further, ASDB has not
evaluated whether such fees cover the costs of the
services provided.
Recommendation—ASDB should ensure that fees
cover the cost of all services provided by regional
cooperatives by assessing operations, tracking
costs, and developing appropriate fees.
ASDB should review regional cooperative service fees and
strengthen its operations
ASDB needs to improve its information technology practices
In 2009, the Arizona Department of Administration’s
Information Security group assessed ASDB’s infor-mation
technology (IT) environment. This assess-ment
identified deficiencies and made several
recommendations. Although ASDB tried to address
the deficiencies, this audit identified the following IT
security control weaknesses:
• No risk assessment or security reviews of the IT
environment have been done.
• The IT network does not have adequate controls
to secure it from hackers.
• There is no effective process for updating com-puters
and servers, which are running critical
systems on outdated software.
ASDB also does not have a comprehensive disaster
recovery plan and does not properly test or backup
data. As a result, ASDB may not be able to meet
federal and state requirements to protect the privacy
of it students and staff.
Recommendations—ASDB should:
• Strengthen IT security controls.
• Address disaster recovery deficiencies.
• Improve data backup.
TABLE OF CONTENTS
continued
Introduction 1
Finding 1: ASDB can do more to promote student success 9
ASDB aims to prepare students for future 9
ASDB uses several assessments to measure student progress 10
Test scores showed some academic progress, but comparative information
for assessing program success is limited 11
ASDB uses commonly used practices but can work to improve 15
Recommendations 24
Finding 2: ASDB should examine regional cooperative
program service fees and strengthen program operations 27
ASDB provides services to students at local school districts through
its regional cooperative program 27
ASDB should examine fees for regional cooperative programs services 29
Regional councils’ role in fee-setting needs review 34
Regional cooperatives are not consistent in tracking resources 37
Recommendations 38
Finding 3: ASDB needs to improve its information technology
practices 41
IT systems used extensively and contain sensitive data 41
page i
Office of the Auditor General
TABLE OF CONTENTS
continued
ASDB has not addressed critical IT weaknesses 41
Recommendations 47
Sunset Factors 49
Appendix A: Test results a-i
Appendix B: Methodology b-i
Agency Response
Tables
1 Student Enrollment by Type of Disability
School Year 2011-2012 2
2 Schedule of Revenues, Expenditures, and Changes in Fund Balance
Fiscal Years 2009 through 2012
(Unaudited) 7
3 Services Provided by Regional Cooperative Staff
School Year 2011-2012 30
4 Regional Cooperative Membership Fee Structure
School Year 2011-2012 31
5 Regional Cooperative Reimbursements to Districts
School Year 2011-2012 32
6 Example of Differences in Regional Cooperative Service Costs
School Year 2011-2012 33
page ii
State of Arizona
TABLE OF CONTENTS
concluded
Figures
1 Regional Cooperatives, School Districts, and Students Served
As of April 2012 4
2 Spring 2011 AIMS Test Results for ASDB Students and State-wide Students 12
3 Mississippi Joint Legislative PEER Committee’s Structured
Fee-Setting Process Developed for State Government 35
4 Spring 2008, 2009, 2010, and 2011 AIMS Math Test Results
for ASDB Students and State-wide Students a-i
5 Spring 2008, 2009, 2010, and 2011 AIMS Reading Test Results
for ASDB Students and State-wide Students a-i
page iii
Office of the Auditor General
ASDB educates students with sensory
impairments
Programs and responsibilities
ASDB was established in 1912 to provide education to students with sensory
impairments such as deafness or blindness. ASDB enrolled 478 students at its
on-campus schools in the 2011-2012 school year (see Table 1, page 2). In
addition, ASDB provided services to 1,190 additional students in school
districts and 299 preschool students throughout the state during the 2011-
2012 school year.
In accordance with state law, ASDB provides educational programs for chil-dren
and students from birth through 21 years who have a vision and/or hear-ing
loss (see textbox for ASDB’s mission). According to statute, school districts
must arrange for a placement and evaluation team for students with a vision
and/or hearing impairment.
The team includes the child’s
parent or guardian as well as
school district and ASDB rep-resentatives.
This team deter-mines
the appropriate educa-tional
placement for the stu-dent
based on his or her indi-vidualized
education program.
Students can attend a local
school district, charter school,
or one of the ASDB campuses.
As of April 2012, the 1,668 students ASDB served were enrolled in the following
schools and/or programs:
• Arizona Schools for the Deaf and Blind (110 students at the Arizona
School for the Deaf and 85 students at the Arizona School for the
Blind)—Two schools, the Arizona School for the Deaf and the Arizona
School for the Blind, make up the ASDB Tucson campus. According to
ASDB officials, students can live on campus as residential students or
attend as day students if they live within 60 miles of the campus. As of
April 2012, 70 students lived on campus. Both schools are accredited by
page 1
Scope and Objectives
INTRODUCTION
The Office of the Auditor
General has conducted a
performance audit and
sunset review of the
Arizona State Schools for
the Deaf and the Blind
(ASDB) pursuant to an
October 26, 2010,
resolution of the Joint
Legislative Audit
Committee. This audit was
conducted as part of the
sunset review process
prescribed in Arizona
Revised Statutes (A.R.S.)
§41-2951 et seq. This
performance audit and
sunset review addresses
(1) how ASDB can increase
its use of best practices to
promote its students’
success, (2) improvements
that ASDB should make to
the operations of its
regional cooperatives
program, and (3) the need
to better protect student
data and make other
improvements to ASDB’s
information systems
management. The report
also includes responses to
the statutory sunset
factors.
Office of the Auditor General
ASDB Mission: To work together with
parents, school districts, advocacy
organizations, and business and community
members to create nurturing environments in
which children with a vision or hearing loss
feel valued, develop their abilities, strive to
achieve academic excellence, and develop
skills to help them become productive and
responsible members of society.
Source: Fiscal Years 2010-2013 master list of state
government programs.
AdvancED.1 The Arizona School for the Deaf offers educational and
support services, including instruction in a direct communication
environment and counseling (see textbox), as well as training that
teaches students with cochlear implants to hear and understand speech
and other sounds. At the Arizona School for the Blind, services are
provided based on an expanded core curriculum that includes state
standard curriculum and special services such as orientation and mobility
training, braille, visual efficiency training, assistive technology, and
compensatory skills and tools. Both schools also offer other services
based on students’ needs, including activities of daily living; social skills;
occupational, physical, and speech therapy; and residential services.
• Phoenix Day School for the Deaf (283 students)—According to
ASDB officials, the Phoenix school educates students who are deaf or
hard-of-hearing and live within 60 miles of the metropolitan Phoenix area.
It provides educational and support services similar to the Arizona School
for the Deaf. The school supports students developing two languages—
1 AdvancED is an organization of public and private schools in the United States and other countries world-wide that
accredits schools based on adherence to quality standards in several areas, including curriculum, instructional design,
and assessment practices. The organization was formed in 2006 from the North Central Association Commission on
Accreditation and School Improvement, the Southern Association of Colleges and Schools Council on Accreditation
and School Improvement, and the National Study of School Evaluation.
page 2
State of Arizona
Direct Communication Environment—
Direct communication and access are a
critical part of education and language
development. Students who are deaf or
hard-of-hearing interact directly with
teachers, staff, and peers every day in
the classroom, cafeteria, after-school
program, and residential program. Direct
access to instruction and peer
interaction leads to enhanced
educational, social, and emotional
development; and allows a greater
degree of independence, self-confidence,
and self-advocacy.
Source: Arizona School for the Deaf Web site.
Table 1: Student Enrollment by Type of Disability
School Year 2011-2012
1 According to ASDB officials, “other” refers to a student with a sensory impairment who also has a medical
condition or a physical impairment.
2 According to ASDB officials, multiple disabilities are not identified in preschool children but are identified at a
later age.
Source: Auditor General staff analysis of ASDB’s April 2012 report, Agency enrollment: school year 2011-2012.
Program
Deaf or
Hard-of-
Hearing
Visually-
Impaired
Multiple
Disabilities
with Sensory
Impairment
Multiple
Disabilities
with Severe
Sensory
Impairment
Other with
Sensory
Impairment 1
Total
Students
ASDB Campuses
Arizona School for
the Blind
0 35 22 28 0 85
Arizona School for
the Deaf
79 0 16 15 0 110
Phoenix Day School
for the Deaf
211 0 40 32 0 283
Regional Cooperatives
Desert Valleys 160 51 80 92 1 384
Eastern Highlands 34 17 42 19 3 115
North Central 99 28 69 58 9 263
Southeast 130 36 88 39 15 308
Southwest 57 10 29 23 1 120
Preschool2 154 107 0 0 38 299
Total 924 284 386 306 67 1,967
American Sign Language (ASL) and English—and its curriculum parallels the
curriculum provided by public schools with modifications to meet students’
communication needs. According to ASDB officials, the school also offers
intensive instruction in functional and daily living skills for students who need it.
The school is accredited by AdvancED.
• Regional cooperatives (1,190 students)—ASDB provides educational and
support services in students’ local schools through five regional cooperatives
located in various parts of the State (see Figure 1, page 4). The Legislature first
authorized ASDB to establish regional cooperatives in 1988 to provide various
services that would enable districts to serve sensory-impaired students in a cost-effective
way and enable these students to reach their individual potentials by
providing access to the general education curriculum in district schools.
According to ASDB officials, the regional cooperatives provide access to a pool
of specially trained personnel and equipment, such as sign language interpreters
and braille-writer machines.
In addition to enrolling students at its campuses or in regional cooperatives, ASDB
provides services through the following programs:
• Birth to 3 program (273 children)—In cooperation with the Arizona Early
Intervention Program (AzEIP, see textbox on page 18), ASDB provides federally
mandated services for families of/and children ages birth to 3 who have hearing
or vision loss or who are deaf-blind. The program provides a comprehensive and
coordinated interagency system of early intervention services in the child’s home
and is designed to work in cooperation with other agencies and programs to
support the child and family’s needs. In addition to assessments that determine
if an infant or toddler is eligible for the program and to plan appropriate services,
the AzEIP program offers service coordination, assistive technology devices,
family training, physical and occupational therapy, and speech-language
pathology services.
• Preschool program (299 students)—ASDB
provides preschool education to eligible children,
ages 3 to 5, at its campuses in Tucson and
Phoenix and in classrooms in public schools
throughout Tucson and Phoenix. The services
offered to the children include preschool education,
educational assessment, vision and audiological
assessments, orientation and mobility services,
and speech therapy.
ASDB’s campuses and other programs serve students
with vision or hearing loss, including students with
multiple disabilities if at least one of the disabilities is a
visual or hearing impairment (see textbox). In the 2011-
2012 school year, most students ASDB served state-page
3
Office of the Auditor General
Multiple disabilities—Learning and developmental
problems that require special education and related
services and that result from two or more of (1)
hearing impairment, (2) orthopedic impairment, (3)
moderate intellectual disability, and (4) visual
impairment, or any of those conditions concurrently
with mild intellectual disability, emotional disability, or
specific learning disability.
Multiple disabilities with severe sensory
impairment—Multiple disabilities that include (1)
severe visual or hearing impairment with another
severe disability or (2) severe visual and severe
hearing impairments.
Source: A.R.S. §15-761
page 4
State of Arizona
Source: Auditor General staff analysis of data received from ASDB’s regional cooperatives as of April 2012.
Figure 1: Regional Cooperatives, School Districts, and Students Served
As of April 2012
Mohave
Coconino
Yavapai
La Paz
Yuma
Pinal
Graham
􀀪􀁕􀁈􀁈􀁑􀁏􀁈􀁈
Pima
Cochise
Santa
Cruz
Maricopa
Gila
Navajo Apache
North Central Regional Cooperative
􀁴􇐀􀀁􀄀 􀀔􁐀􀀕􁔀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀓􁌀􀀗􁜀􀀔􁐀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑅
Eastern Highlands
Regional Cooperative
􀁴􇐀􀀁􀄀 􀀓􁌀􀀒􁈀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀒􁈀􀀒􁈀􀀖􁘀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑓
Southeast Regional Cooperative
􀁴􇐀􀀁􀄀 􀀕􁔀􀀓􁌀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀔􁐀􀀑􁄀􀀙􁤀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑄
Desert Valleys Regional Cooperative
􀁴􇐀􀀁􀄀 􀀕􁔀􀀒􁈀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀔􁐀􀀙􁤀􀀕􁔀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑓
Southwest Regional Cooperative
􀁴􇐀􀀁􀄀 􀀚􁨀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀒􁈀􀀓􁌀􀀑􁄀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅐀
page 5
Office of the Auditor General
wide had a hearing loss, with smaller numbers of students with a vision loss or multiple
disabilities (see Table 1, page 2).
Board and staff
ASDB’s Board of Directors (Board) is responsible for the governance of ASDB,
including setting policy and appointing, evaluating, and determining whether or not to
offer a new contract to ASDB’s Superintendent. It has ten members, including the
Governor and the State’s Superintendent of Public Instruction who serve as ex officio
members. The Governor appoints the remaining members, who serve 3-year terms.
The appointed members include:
• One member from the Commission for the Deaf and the Hard-of-hearing;
• One member from the Governor’s Council on Blindness and Visual Impairment;
• One school district employee who works with his or her district’s program for
sensory impaired pupils; and
• Five additional members. A.R.S. §15-1321 requires the Governor to give
preference to people with experience and knowledge of sensory-impaired
education for three of these members.
ASDB has staff at its three school campuses and at its five regional cooperatives that
are located in various parts of the State. As of May 2012, ASDB reported that it had
803 full-time equivalent (FTE) positions, with 256 vacancies. The vacancies included
78 teachers; 38 instructional assistants; 47 educational interpreters, audiologists, and
transcribers; 9 drivers; and 84 various other positions.
ASDB’s staffing includes the following:
• Administration—The administrative staff include a superintendent who serves as
the executive officer for ASDB, an assistant superintendent, and principals for
each school. In addition, ASDB has directors over operations, regional
cooperatives, information technology, and human resources; a staff development
specialist; and an accountability specialist.
• Teaching and educational support—As of May 2012, ASDB employed 227.75
teachers and 20 supervisory teachers. Educational support includes 11.25
audiologists, 4.25 braillists, 1 ASL specialist, 3.25 speech/language pathologists,
and 65.75 educational interpreters. The educational interpreters work at the
regional cooperatives. ASDB’s teachers and other educational staff generally
have special training and certification in communicating with and teaching
students with sensory impairments.
page 6
State of Arizona
• Other—ASDB’s on-campus staff in Tucson also include night supervisors,
residential hall team leaders, and live-in staff for the student dormitories. These
staff also include teaching parents, who are educators responsible for working
with students on goals in areas such as personal care, recreation and leisure,
and domestic life. In addition, ASDB’s operations staff include custodial,
maintenance, security, food service, and equipment repair staff as well as full-time
and part-time drivers.
Budget and finances
As shown in Table 2 (see page 7), ASDB received approximately $55.5 million, $56.5
million, $54.7 million, and $53.8 million in annual net revenues in fiscal years 2009
through 2012, respectively. These revenues included:
• Special education voucher monies from the Arizona Department of
Education (ADE) to reimburse ASDB for educational costs based on its
enrollment—These monies are provided for students at ASDB’s three campus
schools and some students enrolled in ASDB’s regional cooperative program.
In the 2011-2012 school year, the voucher amount was $19,122.39 for each
visually-impaired student and $19,008.02 for each hearing-impaired student.
For each student who receives services through the regional cooperative
program, ASDB and the student’s district decide whether ASDB or the district
will collect the voucher monies.
• Payments from school districts for services provided by the regional
cooperative program—These include membership fees to participate in the
regional cooperative program and fee-for-service payments for students whose
voucher monies are retained by the district. Fee-for-service payments vary
depending on the level of service provided by ASDB. In the 2011-2012 school
year, the payments ranged from $2,800 annually for a student receiving 1 hour
per month of services to $21,500 annually for a student receiving 10 to 15 hours
per week of services (See Finding 2, pages 27 through 39, for additional
information on the fees charged for services provided through ASDB’s regional
cooperative program).
• State General Fund appropriations made directly to ASDB—State General
Fund appropriations help bridge the gap between the cost of educating ASDB
students and the amounts provided by special education vouchers and fees
paid by school districts. In fiscal year 2012, ASDB received a $20.8 million State
General Fund appropriation.
As shown in Table 2, ASDB’s total expenditures ranged between nearly $55.2 million
in fiscal year 2009 to approximately $54.5 million in fiscal year 2012. Most of ASDB’s
expenditures are for personal services and related benefits. These monies pay for
teachers and other staff at the three on-campus schools, teachers in the regional
page 7
Office of the Auditor General
1 Amount is primarily composed of educational reimbursements from the Arizona Department of Education based on enrollment and is determined by
statutory formula. The amount also includes federal grant revenues that are either received directly or passed through from the Arizona Departments of
Economic Security or Education.
2 Amount consists of revenues received from Arizona school districts for services rendered by ASDB’s regional cooperatives on a fee-for-service basis.
3 Amount primarily consists of interest and rental income.
4 Amount consists of transfers to the State General Fund in accordance with Laws 2008, Ch. 285, §46; Laws 2010, Ch. 1, §148 and 7th S.S., Ch. 3, §8; and
Laws 2011, Ch. 24, §§108, 129, and 138 to provide support for state agencies.
5 Amount primarily consists of transfers to the Arizona Department of Economic Security for required matching to obtain federal monies. According to
ASDB, the fiscal year 2009 required match was not made until fiscal year 2010; therefore, the transfer is reported in fiscal year 2010. Similarly, the fiscal
year 2012 required match was not made until August 2012; therefore, it will be reported in fiscal year 2013.
6 According to ASDB, end-of-year fund balances consist of revenues from several dedicated funding sources such as federal grants, Proposition 301
(2000) sales taxes, and educational reimbursements from the Arizona Department of Education. The balances are generally needed for cash flow at the
beginning of the next fiscal year or are restricted for specific purposes. For example, in order to pay the payroll costs for current 12-month employees
and purchase equipment, supplies, and materials needed for the start of the school year, the balances are needed in July and August since educational
reimbursements from the Arizona Department of Education, fees for services, or membership fees are not received until late September.
Source: Auditor General staff analysis of the Arizona Financial Information System (AFIS) Accounting Event Transaction File for fiscal years 2009 through 2012
and the AFIS Management Information System Status of General Ledger-Trial Balance screen for fiscal years 2010 through 2012.
Table 2: Schedule of Revenues, Expenditures, and Changes in Fund Balance
Fiscal Years 2009 through 2012
(Unaudited)
2009 2010 2011 2012
Revenues:
State General Fund appropriations $ 21,351,663 $ 21,580,479 $ 21,511,083 $ 20,802,910
Intergovernmental1 31,373,770 31,646,493 29,759,177 29,544,022
Educational and support service fees2 2 ,216,073 2 ,949,195 2 ,913,044 2 ,885,938
Other3 515,669 336,512 484,947 574,821
Gross revenues 55,457,175 56,512,679 54,668,251 53,807,691
Remittances to the State General Fund (12,034) (1,292)
Net revenues 55,445,141 56,511,387 54,668,251 53,807,691
Expenditures and transfers:
Personal services and related benefits 44,215,881 43,421,888 40,744,344 42,882,990
Professional and outside services 3,563,179 3,215,689 3,943,356 3,550,435
Travel 310,034 300,216 289,665 283,635
Food 255,407 231,084 232,703 237,015
Aid to individuals 1,110
Other operating 5,798,761 5,783,749 6,582,648 4,833,542
Equipment 1,034,733 2,100,684 2,451,489 2,715,179
Total expenditures 55,179,105 55,053,310 54,244,205 54,502,796
Transfers to the State General Fund4 157,200 18,200 531,100 616,400
Transfers to other agencies5 1,063,064 461,882
Total expenditures and transfers 55,336,305 56,134,574 55,237,187 55,119,196
Net change in fund balance 108,836 376,813 (568,936) (1,311,505)
Fund balance, beginning of year 6,506,384 6,615,220 6,992,033 6,423,097
Fund balance, end of year6 $ 6,615,220 $ 6,992,033 $ 6,423,097 $ 5,111,592
cooperative program who travel to the surrounding school districts in their respective
regions throughout the State, and administrative staff. These expenditures also
include salaries and benefits for the staff who provide student transportation to and
from the day school programs, which totaled approximately $2.9 million in fiscal year
2011, according to the fiscal year 2011 Annual Report of the Arizona Superintendent
of Public Instruction and other financial information obtained from ASDB.
page 8
State of Arizona
ASDB can do more to promote
student success
FINDING 1
page 9
ASDB aims to prepare students for future
ASDB’s mission is to work with parents, school districts, and others to enable
children with a vision or hearing loss to develop their abilities, strive to achieve
academic excellence, and develop skills to help them become productive and
responsible members of society. This mission aligns with ASDB’s statutory
responsibility to provide educational services, including instruction in a direct
communication environment, so that deaf, hard-of-hearing, and visually-impaired
students may become self-sustaining and useful citizens.
ASDB’s surveys of recent graduates show that many of its on-campus
students either continue their education or begin working, either independently
or with supports, such as a job coach. In 2011, ASDB reported that the Arizona
School for the Blind had 13 graduates, the Arizona School for the Deaf had 14
graduates, and the Phoenix Day School for the Deaf had 15 graduates.
Surveys conducted approximately 1 year after the students graduated
indicated that the students became involved in a variety of activities. For
example:
• Out of 13 survey respondents who graduated from the Arizona School for
the Blind in 2011, 9 reported that they were participating in work enclave
programs through the Department of Economic Security. Work enclaves
are competitive work site jobs where workers with disabilities are
supervised by program staff and receive a special wage commensurate
with their abilities.
• All 6 2011 graduates of the Phoenix Day School for the Deaf who
responded to the survey and 10 of the 14 respondents from the Arizona
School for the Deaf reported that they were in college or community
college, working, or volunteering. For example, one graduate worked part-time
as a physical therapist assistant after graduation and then resigned
to attend Gallaudet University where he is studying physical therapy.
Another graduate volunteers at the public library for 6 hours per week, a
third works in a supported-employment program sponsored by the
Department of Economic Security, and three graduates were attending a
community college for the deaf in Texas.
The Arizona State Schools
for the Deaf and the Blind
(ASDB) can make
improvements in its use of
best practices to help
ensure that its students
make good educational
progress and are prepared
for their future. Although
ASDB uses standardized
tests to assess individual
student progress, these
tests are somewhat limited
in their ability to assess
ASDB’s students’ progress
and provide relatively
limited information for
comparing ASDB to other
schools that educate
similar students. Thus,
attention to best practices
recommended by experts
and officials at other
schools is particularly
important. ASDB follows
many of these best
practices, including using
technology and modifying
instruction and services to
meet students’ particular
needs.
In four respects, however,
ASDB can strengthen its
efforts. These are:
• Improving its early inter-vention
program; • Seeking ways to increase
students’ access to
highly qualified teachers; • Compiling and using
information about its
graduates to improve its
programs; and • Studying differences in its
students’ test scores and
establishing expectations
regarding practices to
improve students’ test
scores.
Office of the Auditor General
ASDB uses several assessments to measure student
progress
To monitor students’ progress, ASDB relies on several different assessment
mechanisms. These include the same standardized test all Arizona students take, as
well as additional standardized tests, including the Measures of Academic Progress
(MAP), that provide more information on individual student progress. In addition, at
least once a year, ASDB staff will review each student’s progress toward the individual
goals established in his or her Individualized Education Program (IEP) (see textbox,
page 11). Each student’s IEP determines what assessments will be used to measure
the student’s progress, and results are reviewed when the IEP is updated.
ASDB frequently uses the following tests:1
• Arizona’s Instrument to Measure Standards (AIMS)—This is the standardized
assessment taken by all Arizona students in all school districts. The federal No
Child Left Behind Act requires that each state adopt standardized assessments
that align with state standards to demonstrate adequate yearly progress toward
the goal of narrowing achievement gaps. The State of Arizona uses AIMS (see
textbox, page 11) as its standards-based assessment.2 Arizona does not
require special education students to pass the test to meet the requirements for
a high school diploma unless their IEP requires it.
• Measures of Academic Progress (MAP)—This test, created by the Northwest
Evaluation Association (NWEA), assesses the same content as the AIMS,
according to an NWEA official. However, it is an interactive form, meaning that
it does not test a student on more advanced concepts if he/she did not answer
the initial basic concept question correctly. According to ASDB, this type of test
is particularly useful for students who are not performing at grade level because
it provides more information about students’ actual performance levels and their
progress over time than the AIMS does. ASDB administers the test to only some
on-campus students. ASDB officials reported that ASDB encourages all
students to take the MAP if they are able to do so. In spring 2011, approximately
59 percent of ASDB on-campus students took a MAP reading and/or math test.
1 In addition to AIMS and MAP, ASDB reported that it uses other assessments to measure student progress. For example,
it uses the Stanford Achievement Test (SAT-10) in second and ninth grades, as required by the Arizona Department of
Education. In addition, ASDB uses Teaching Strategies GOLD, another Arizona Department of Education required test
for special education children in preschool and kindergarten. For children aged birth to 3 years, ASDB reported that it
also uses the Developmental Assessment of Young Children test for deaf children and the Oregon Project for blind
children to assess the children’s cognitive skill level. ASDB also reported that it uses the 6-Traits Writing Rubric to
evaluate student writing samples, the Fairview assessment focusing on American Sign Language development, the
STAR Reading assessment, Work Sampling—an observational assessment containing grade-level samples of what
students should know and how they would demonstrate their knowledge—and classroom-type tests.
2 This report uses AIMS to refer to both AIMS and AIMS A, the alternate assessment used for some students. Both tests
report student results in the same way, indicating that the student exceeds, meets, approaches, or falls far below
standards.
page 10
State of Arizona
Arizona does not require
special education students
to pass the AIMS test to
obtain a high school
diploma unless their IEP
requires it.
Tests scores showed some academic progress, but
comparative information for assessing program success
is limited
ASDB students, on average, underperformed on standardized tests, although they
made some progress throughout their school years. For several reasons, however,
standardized tests such as AIMS and MAP are limited in their ability to assess the
progress of students with these types of impairments, and state-wide information that
would allow comparisons between ASDB and other Arizona schools educating similar
students is also limited.
Most ASDB students who took AIMS did not meet standards—Students
attending ASDB, either on one of its campuses or through the regional cooperatives,
generally scored lower on AIMS than did Arizona students as a whole. Some ASDB
students passed and even exceeded standards on the AIMS, but most did not. As
shown in Figure 2 (see page 12), in spring 2011, only 5 percent of ASDB students
exceeded standards, and only 25 percent met standards when they took the AIMS
math test in 3rd through 12th grades. By comparison, 23 percent of all students
state-wide who took AIMS exceeded standards, and 36 percent met standards for
math in spring 2011. Similarly, only 2 percent of ASDB students exceeded, and 34
page 11
Office of the Auditor General
Assessment terms
Individualized Education Program (IEP)—Every child with a disability must have an IEP that shows the child’s level
of achievement, measurable annual goals, how progress toward the goals will be measured, and what services will
be provided to the child. The goals may include passing the AIMS if appropriate for the child, but Arizona Revised
Statutes (A.R.S.) §15-763 states that a special education student does not need to pass the AIMS to graduate from
high school unless this is required by the student’s IEP. A team that includes the child’s parent or guardian develops
the IEP and updates it at least annually. The federal Individuals with Disabilities Education Act, Arizona statutes, and
Arizona Department of Education regulations specify the requirements the IEP must meet.
Arizona’s Instrument to Measure Standards (AIMS) and AIMS Alternate (AIMS A)—Tests students’ grade-level
mastery of state academic standards in writing, reading, math, and science. AIMS A is an alternate assessment
based on alternate achievement standards for students with significant cognitive disabilities. Both AIMS and AIMS A
test students in 3rd through 8th grades and in high school beginning in 10th grade (or in 9th grade if the student
repeats that grade) until they pass the test because it is a graduation requirement for most Arizona students. Special
education students are not required to pass the test to receive a high school diploma unless stipulated in their IEP.
Test scores are classified into four levels: exceeds, meets, approaches, and falls far below standards, with exceeds
and meets defined as passing scores.
Measures of Academic Progress (MAP)—Nationally normed test developed by the NWEA of language usage,
reading, math, and science that uses an equal interval scale to allow charting progress from year to year. The test
adapts to a student’s performance by offering questions based on whether the student answered previous questions
correctly. ASDB tests on-campus students in 2nd through 12th grades.
Source: Auditor General staff analysis of information about AIMS, AIMS A, and the IEP obtained from the Arizona Department of Education Web site,
information about MAP from the Northwest Evaluation Association (test publisher) Web site, and A.R.S. §15-763.
In spring 2011, 5 percent
of ASDB students
exceeded standards, and
25 percent met standards
on the AIMS math test.
percent met standards in reading, compared to 9 percent and 65 percent,
respectively, for all students state-wide who took the AIMS reading test.
Approximately two-thirds of ASDB students who took the AIMS math or reading
tests did not meet the standards. AIMS test results for 2008 through 2010 show
that, in those years, ASDB students also had much lower rates for meeting and
exceeding the standards than students state-wide (see Appendix A, page a-i).
page 12
State of Arizona
Source: Auditor General staff analysis of AIMS and AIMS A spring 2011 test scores for all ASDB students enrolled in
the 2011-2012 school year, including on-campus students and regional cooperative students for whom ASDB
receives voucher funding, and state-wide AIMS and AIMS A results for spring 2011 published October 2011
by the Arizona Department of Education in its 2011 Technical Report.
Figure 2: Spring 2011 AIMS Test Results for ASDB Students and State-wide Students
0
10
20
30
40
50
60
70
Falls Far Below Approaches Meets Exceeds
Percent of Students
Reading
ASDB
State-wide
0
10
20
30
40
50
60
Falls Far Below Approaches Meets Exceeds
Percent of Students
Math
ASDB
State-wide
MAP results show students made some progress but were still testing
well below grade level—ASDB students’ test scores for MAP were well below
national norms, which are based on a stratified sampling of students throughout the
United States. ASDB students showed less improvement from one year to the next
during the elementary school years as compared to national norms for all students.1
However, the test is not separately normed for deaf or blind students. Beginning in
5th and 6th grades, ASDB students improved their performance in reading and
math, respectively, compared to national norms. Even so, ASDB students started at
a much lower level than national norms, so while limited growth occurred after 5th
and 6th grades and continued in high school, it was not sufficient to bring students’
scores within reach of national norms (see discussion of early intervention programs,
pages 18 through 21, for reasons ASDB students started at a lower level).
Specifically:
• ASDB on-campus students’ average MAP scores in 2nd grade were in the first
to second percentile in reading and the third to fourth percentile in math. This
result indicates that nearly all students nationally who took the MAP received
higher scores than ASDB students who took the test.
• By the 11th grade, ASDB students who took the MAP scored on average the
same as 3rd-grade students would in reading and scored slightly below the
average 4th-grade student in math. This reflects a slight gain in performance,
with results at the fifth to sixth percentile in reading and the seventh to eighth
percentile in math. On average, 11th-grade students nationally who took the
MAP scored at approximately the 50th percentile and scored the same as a
typical-11th grade student would.
Standardized test scores are limited as indicators of program
success—For several reasons, great care must be taken in inferring conclusions
from these results. Key limitations include natural disadvantages ASDB students
may face in taking standardized tests. Additionally, there is little comparative
information about scores attained by similar students in other settings in Arizona or
in schools elsewhere in the United States. Specifically:
• Students who are deaf or hard-of-hearing and students who are blind or
visually-impaired may have difficulty taking standardized tests—Students
attending ASDB have hearing and/or visual impairments or multiple disabilities
(see textbox, page 3, for information on multiple disabilities). According to
experts, language deficits and testing barriers make it more difficult for these
students to perform at national or state norm levels on any standardized tests.
Despite accommodations such as braille versions of tests and having test
directions read aloud or signed, barriers that affect student performance still
exist. For example, deaf students do not learn English in infancy, but the tests
are administered in English so deaf students are taking the test in their second
1 Auditors analyzed ASDB students’ spring test results for the MAP test for 2006 through 2011 and compared them with
the spring 2011 national results published by NWEA.
page 13
Office of the Auditor General
According to experts,
language deficits and
testing barriers make it
more difficult for sensory-impaired
students to
perform at national or
state norm levels on any
standardized test.
language. Additionally, blind students are unable to see illustrations, such as
graphs, used in standardized math tests.
• ASDB students’ scores cannot be reliably compared with results for
other sensory-impaired students in Arizona or nation-wide—Within
Arizona, the available information regarding student test scores makes it
difficult to compare ASDB students’ performance with the performance of
similar students throughout the State. A key reason is the way in which school
districts must report special education students’ test scores. Specifically, to
comply with Family Educational Rights and Privacy Act regulations, when
school districts submit test scores to the Arizona Department of Education,
they report all students with disabilities under the broad category of special
education. They do not report students’ specific disabilities because such
categorization could enable students to be individually identified in published
reports. Therefore, sensory-impaired students’ test scores are reported in the
same category as students with learning disabilities, developmental delays,
and other disabilities. Further, although the Arizona Department of Education
has data regarding all Arizona students, including their specific disabilities that
could be matched with test scores, Arizona Department of Education officials
reported that this specific data may not be complete. As a result, the available
information does not provide an accurate way to compare the State’s entire
population of sensory-impaired students by disability.
Similar problems exist when attempting to compare ASDB students to
sensory-impaired students in other states. First, each state administers
different tests to measure students against their state’s standards. This makes
it difficult to compare students’ progress across states. Second, states differ
in the degree to which they require sensory-impaired students to take
standardized tests required of other students. Some deaf and blind schools
must participate in their states’ standardized testing. For example, students at
Perkins School for the Blind in Massachusetts are required to pass the state
test in order to obtain a high school diploma. Additionally, Alabama requires
all high school students to take the state test to graduate with a diploma, and
eligible students with disabilities who do not pass the test can obtain an
occupational diploma instead of the regular high school diploma. However,
similar to Arizona, at least two other states do not make passing the
standardized test a graduation requirement for all deaf and blind students.
Specifically, Florida School for the Deaf and the Blind students and Texas
students who are deaf or blind can receive waivers from testing requirements
for a high school diploma as long as the students can demonstrate in some
other way that they have met state standards. Additionally, at least two states’
deaf and blind schools have admission policies that restrict or deny admission
of severely impaired students. This would greatly impact the comparability of
those schools’ test results with ASDB’s test results as students with severe or
multiple impairments often struggle with passing standardized tests.
page 14
State of Arizona
When school districts
submit test scores to the
Arizona Department of
Education, they report all
students with disabilities
under the broad category
of special education.
page 15
Office of the Auditor General
Although there is a lack of comparison information regarding blind and multiply
disabled students’ test scores, some limited studies have been conducted for
deaf students. For example, a 2005 study found that the SAT-9 reading
comprehension score for 17- and 18-year-old deaf and hard-of-hearing
students was approximately equivalent to that of 4th-grade hearing students,
and a 2012 longitudinal study reported that deaf 17-year-olds’ SAT-9 math
scores approached the 6th-grade level.1,2 In addition, test results for a small
number of students at a small number of schools for the deaf nation-wide
suggest that ASDB deaf and hard-of-hearing students’ scores are similar to
those of their peers at other schools.3
ASDB uses commonly used practices but can work to
improve
Given the limitations of test results as a way to gauge ASDB’s success, auditors
looked for other ways to assess ASDB’s efforts. One commonly used assessment is
the degree to which an organization employs “best practices”—that is, those
approaches and techniques that experts, researchers, and practitioners have identified
as likely characteristics of a well-performing program. Although scientific research is
limited regarding what works in educating deaf and visually-impaired students, experts
have identified several commonly used practices. ASDB already follows a number of
these practices. However, it should focus additional effort in four key areas in order to
promote its students’ success: early intervention, increasing its students’ access to
highly qualified teachers, using surveys of its graduates to identify ways to improve its
programs, and developing ways to improve students’ scores on standardized tests.
Research is limited—Experts in the fields of deaf and blind education have
conducted extensive reviews of existing research and concluded that there is not a
large body of empirical research to draw upon to establish evidence-based
practices.4 This contrasts with research in educating children with more common
characteristics such as learning disabilities. However, experts at Gallaudet University,
a prominent university for deaf students in Washington D.C., and Perkins School for
the Blind in Massachusetts, as well as officials at deaf and blind schools in Texas
1 Gallaudet Research Institute. (n.d.). Literacy & deaf students. Retrieved, July 10, 2012, from http://www.gallaudet.edu/
gallaudet_research_institute/publications_and_presentations/literacy.html
2 Qi, S. & Mitchell, R.E. (2012). Large-scale academic achievement testing of deaf and hard-of-hearing students: past,
present, and future. Journal of Deaf Studies and Education, 17(1), 1-18.
3 The results from the other schools are preliminary. The test publisher cautions that because of the small number of test
scores included and the lack of stratification, the results should not be used for comparison as part of a decision-making
process. The data does represent a set of grade-level averages of test results of students identified as being deaf over
a number of years.
4 Luckner, J.L., & Handley, C.M. (2008). A summary of the reading comprehension research undertaken with students who
are deaf or hard-of-hearing. American Annals of the Deaf, 153(1), 6-36; and Douglas, G., McCall, S., McLinden, M., &
Pavey, S. (2009). International review of the literature of the evidence of best practice models and outcomes in the
education of blind and visually-impaired children. Trim, Co. Meath, Ireland: National Council For Special Education.
Test results for a small
number of schools for the
deaf nation-wide suggest
that ASDB deaf and hard-of-
hearing students’
scores are similar to those
of their peers at other
schools.
page 16
State of Arizona
and Florida, shared information with auditors regarding practices they have found
to be effective in educating deaf, hard-of-hearing, and visually-impaired students.
ASDB follows some commonly used practices—ASDB uses some
commonly used practices that are consistent with those identified by the experts
and practitioners auditors interviewed although there is a shortage of direct
evidence demonstrating practices are effective with deaf and blind students.
These include using technology to help students learn and adjusting instruction to
meet students’ needs. Specifically:
• Technology innovations help students learn—Experts and national deaf
and blind advocacy organizations indicated that innovations in technology are
vital to student advancement. These technological innovations help improve
deaf and blind students’ ability to access information. For example, an official
with the National Council of State Agencies for the Blind reported that portable
devices with refreshable braille displays enable blind students to keep up with
note taking and reading requirements in high school and beyond. Braille-reading
devices can allow students to access content as braille text or through
conversion to spoken words. Additionally, these portable devices allow blind
students’ access to Global Positioning Systems, which can enhance their
orientation and mobility skills and increase their independence. Another
assistive technology used by other states’ schools is distributed video in every
classroom. Distributed video uses smart whiteboards that bring the board
content to a screen on the student’s desk, and a swivel hinge allows visually-impaired
students to bring the screen as close as the student needs. Other
states’ schools also use technology to assist with their outreach programs by
providing webinars, online information, and training as well as publications
and other resources to professionals and families.
ASDB uses technology extensively and has developed a technology plan for
fiscal years 2011 through 2014, which identifies several technological
innovations to further make student learning a priority. ASDB already uses
technology such as computers and smart whiteboards in some classrooms,
computers in the library, video telephone booths, and refreshable braille
readers. The plan addresses several areas, including Reading/Language
Arts, Math, Highly Qualified Teachers, American Sign Language (ASL) and
Braille, Parent Involvement, and Technology Literacy. For each area, the plan
identifies a technology strategy and an action step with measurable goals. For
example, by the 2011-2012 school year, ASDB’s goal was to have all teachers
use digital video and other multimedia tools to promote language development,
and according to an ASDB official, this has been implemented. Another 2011-
2012 school year goal was that all students in the Arizona School for the Blind
would have accounts that would allow them to download library books in
braille. According to ASDB, this has also been implemented. Additionally,
ASDB plans to use interactive whiteboards for teaching math during the 2012-
2013 school year. ASDB also plans to build an accessible Web site for parents
ASDB uses technology
such as computers and
smart whiteboards in
some classrooms,
computers in the library,
video telephone, and
refreshable braille readers.
page 17
Office of the Auditor General
that will include trainings and tutorials as well as access to student events,
grades, and achievements for the 2012-2013 school year.
• ASDB modifies instruction and services to student needs—Other states’
deaf and blind school officials indicated that providing expanded curriculum
and individualized instruction, and grouping students based on ability level are
commonly used practices for educating deaf and/or blind students. At least two
other states’ deaf and blind schools have separate programs for students
based on their educational progress and needs. Specifically, the Florida School
for the Deaf and the Blind has three separate high school programs, including
one program that is specifically for students with additional conditions or needs.
Similarly, according to officials at the Texas School for the Blind and Visually-impaired,
their school has four separate academic programs with curriculum
designed to meet students’ needs. These programs include an academic
program designed for students functioning within 2 years of their grade level, an
academic program designed for students who are not yet reading at the first-grade
level, an academic program designed for students functioning more than
2 years below their chronological age, and a basic skills program for students
with multiple disabilities who learn best with consistent routines and meaningful
functional activities.
ASDB serves students with a wide range of needs, including students with
multiple disabilities and severe sensory impairments. Similar to public schools,
ASDB structures some of its classrooms by age and grade. However, ASDB
policy calls for placing students based on the student’s needs, and according
to ASDB staff, ASDB avoids assigning students with a wide range of academic
needs to the same classroom. Thus, an ASDB class may include students
grouped by academic ability level rather than age, and according to ASDB staff,
teachers must adapt instruction to meet each student’s individual needs. By
policy, ASDB classroom sizes are small, with student-teacher ratios ranging
from six to one for multiply disabled students with severe sensory impairments
to ten to one for deaf and hard-of-hearing students in elementary through
middle school grades. Typical classroom sizes range from five to nine students.1
ASDB also offers separate classes for students with additional disabilities or
higher need levels. According to ASDB staff, these classes cover the same
content as required by Arizona state standards, but the way in which the teacher
provides instruction may be different. For example, teachers may provide
reading materials at a lower level, e.g. fifth grade instead of tenth grade, for
those who have difficulty with reading comprehension or reading fluency.
According to ASDB staff, these classes usually also include a full-time teacher’s
aide.
1 Classroom sizes are based on 2011-2012 rosters for the Arizona School for the Blind and the Phoenix Day School for the
Deaf and 2012-2013 rosters for the Arizona School for the Deaf.
ASDB classroom sizes are
small, with student-teacher
ratios ranging
from six to one for multiply
disabled students with
severe sensory
impairments to ten to one
for deaf and hard-of-hearing
students.
Four areas require attention—Although ASDB follows some commonly used
practices, it can strengthen its practices in the following four ways:
• Early intervention and education critical to student success—The earlier
a child is identified as having a sensory impairment and receives services for
the impairment, the faster the child can begin learning the appropriate skills
to adjust to his/her environment. Research shows that the critical intervention
time for a baby who is deaf or hard-of-hearing is the first 3 years after birth,
and that the first 6 months after birth are crucial for the development of
communication and language skills.1 According to two other states’ deaf and
blind school officials, students who begin receiving specialized educational
services late may have missed the critical window when the brain is most able
to develop language, and these students may never catch up.
Experts indicated that early intervention services along with effective and
meaningful parent-child interactions help ensure successful outcomes in
areas such as vocabulary development, verbal reasoning skills, and social
interaction.2 The story of one ASDB student provided by ASDB staff illustrates
the positive outcome of early intervention and parent involvement:
◦ The student began receiving services almost immediately after birth. She
transitioned into preschool at Phoenix Day School for the Deaf and is now
in seventh grade, where she participates in sports, other activities,
and after-school events. In addition to early intervention,
ASDB staff reported that the mother’s involvement has
played a large role in the student’s success. While her
daughter was young, the Spanish-speaking mother began
learning sign language. Although the mother is not fluent in
ASL, she can communicate with her daughter and is very
involved in her daughter’s education by helping with
homework and communicating with her daughter’s teachers.
The student is progressing academically and scored above
the average ASDB student on MAP reading and math tests
in second through sixth grades.
ASDB provides early intervention services to sensory-impaired
students through the AzEIP program (see textbox).
The AzEIP program is responsible for providing early
intervention services to referred children and their families to
support children’s development. ASDB is one of the five
1 The National Agenda (2005). Moving forward on achieving educational equality for deaf and hard-of-hearing students.
Retrieved July 10, 2012, from http://www.ceasd.org/agenda/downloads/natl-agenda-2005-04.pdf
2 American Speech-Language Hearing Association. (2008). Service provision to students who are deaf and hard-of-hearing:
Birth to 36 months [Technical report]. Rockville, MD: Author; and Douglas, McCall, McLinden, & Pavey, 2009.
page 18
State of Arizona
Arizona Early Intervention Program (AzEIP)
The AzEIP is Arizona’s state-wide, interagency
system of supports and services for infants and
toddlers with developmental delays or disabilities
and their families. AzEIP services include
assistive technology devices and services, family
training, physical and occupational therapy,
vision and audiological assessments, orientation
and mobility services, and speech language
pathology services. The federal Individuals with
Disabilities Education Act, Part C, establishes
AzEIP to help provide eligible children and their
families access to services to enhance the child’s
development.
Source: Arizona Department of Economic Security AzEIP Web
site.
Experts indicated that early
intervention services along
with effective parent-child
interactions help ensure
successful outcomes in
vocabulary development,
verbal reasoning skills, and
social interaction.
agencies participating in the AzEIP program.1 ASDB’s AzEIP program
responsibilities for sensory-impaired children include evaluating and assessing
the child’s needs within 45 days of a referral; ensuring that the child has an
appropriate Individualized Family Service Plan (IFSP); providing or arranging for
the services on the IFSP in the appropriate intensity, frequency, and duration;
and participating in the transition and review of the child before the child enters
school. In addition, ASDB is responsible for various other tasks such as
coordinating with other AzEIP agencies, providing information for a state-wide
resource directory, and collecting and reporting data to the Department of
Economic Security.
Although ASDB complies with the 45-day requirement to assess children’s
sensory impairment needs and develop a service plan, it can improve in
regards to its other responsibilities within the AzEIP program. Specifically, as
part of the referral process, after a child has been identified as having a hearing
or visual impairment, ASDB is responsible for assessing the child’s sensory
impairment service needs and developing a service plan that will address these
needs within 45 days of a referral. According to an AzEIP official, ASDB meets
this 45-day time frame requirement. Adhering to this time frame for assessing
and then developing a plan to address service needs is important because
experts indicate that almost half of newborns who are referred from a hearing
screening do not have appropriate followup to determine the presence of a
hearing loss and to initiate appropriate early intervention services.2
However, ASDB should continue its efforts to improve in several other aspects
of its early intervention program. As of June 2012, ASDB had identified the
following areas for improvement:
◦ Coordination with other agencies—According to ASDB staff, it is working
with other state agencies that are part of the AzEIP program to collectively
establish contract services, such as therapists, that will allow referred
children and families to begin receiving services more efficiently. According
to ASDB staff, ASDB also plans to work with the Arizona Department of
Education and the Department of Economic Security to establish uniform
guidelines for the use of services provided to children when they transition
out of the AzEIP program and into schools.
◦ Staff training and certification—According to an ASDB official, ASDB plans
to provide training to its early intervention program staff to ensure that all staff
are using a consistent curriculum for early intervention services when they
work with children and families. In addition, ASDB reported it is taking steps
to ensure that its staff have a Standards of Practice certification as required
1 The five AzEIP participating agencies identified in A.R.S. §8-652 are the Department of Economic Security, ASDB, the
Arizona Department of Health Services, the Arizona Health Care Cost Containment System, and the Arizona Department
of Education. The Department of Economic Security oversees the program.
2 American Speech-Language Hearing Association, 2008
page 19
Office of the Auditor General
As part of the AZEIP
program, ASDB is
responsible for assessing
the child’s sensory
impairment service needs
and developing a service
plan within 45 days of a
referral.
by the AzEIP program, through which staff demonstrate the knowledge
and skills required to provide early intervention services.
◦ Organizational structure and staffing—According to ASDB staff, in June
2011, ASDB appointed a Tucson official to oversee its early intervention
program to help ensure the consistent operation of this program state-wide.
Prior to this change, ASDB’s regional cooperatives were responsible
for coordinating and managing early intervention services to children and
their families, which led to some inconsistencies within ASDB’s early
intervention program. In addition, ASDB is planning to revise staff job
descriptions to more accurately reflect the services it provides to children
and their families within the early intervention program and ensure staff
clearly understand their responsibilities.
◦ Outreach to families—ASDB has developed a new Web site that will
provide more detailed information to the public about resources available
through the AzEIP program as well as descriptions of all the programs
provided by ASDB, including early intervention, preschool, and school-age
programs. In addition, ASDB reported that it plans to use other outreach
mechanisms, including social networking sites such as Facebook,
YouTube, and Twitter, to reach more families that might benefit from its
services.
◦ Delays in starting services—ASDB plans to work with the Arizona
Department of Health Services’ Early Hearing Detection and Intervention
program to develop a new system that will allow ASDB staff access to
infant screening records so they can help ensure any child who fails a
screening receives appropriate assessments and other services in a timely
manner. In addition, ASDB is providing training to its staff to ensure any
delays in services are accurately reported to the Department of Economic
Security. The Department of Economic Security uses this information for
federal reporting requirements, to assess the reasons for the delay in
services, and to take appropriate action, if necessary.
◦ Compliance with state-wide AzEIP program requirements—The
Department of Economic Security’s review of ASDB’s early intervention
program for the period July 2010 through June 2011 found that ASDB did
not provide the required monthly service data to the Department of
Economic Security in a timely manner and included inaccurate information
in its database, which generates the monthly service data. The Department
of Economic Security uses the monthly service data to satisfy federal
government reporting requirements for the AzEIP program. The Department
of Economic Security also reported that ASDB’s IFSPs do not always
contain measurable goals, which are required by federal regulations.
Additionally, the review found that ASDB did not obtain sufficient parent
survey responses from one region of the State. This survey is used to help
page 20
State of Arizona
The Department of
Economic Security’s review
of ASDB’s early intervention
program for the period July
2010 through June 2011
found that ASDB did not
provide accurate service
data in a timely manner.
ensure that parents understand their rights regarding early intervention
services and that early intervention services have helped their children learn
and develop.
ASDB has developed performance improvement plans to address areas of
noncompliance with AzEIP requirements. Additionally, ASDB Information
Technology department has developed a plan to address issues with the
current database, and the official responsible for ASDB’s early intervention
program provided training to staff in December 2011 to help address data entry
practices.
• Highly qualified teaching staff important in
subject matter as well as in teaching techniques—
The federal Individuals with Disabilities Education
Act requires schools to hire highly qualified teachers
to teach students categorized as having disabilities
(see textbox). In addition, the No Child Left Behind
Act requires 100 percent of a school’s teachers of
core academic subjects, such as English,
mathematics, and reading or language arts, to be
highly qualified in the subjects they teach. Therefore,
all ASDB teachers must be highly qualified in
special education, and those who teach core
academic subjects must also be highly qualified in
the subjects they teach. Experts agree that students
make better progress when their teachers are
highly qualified in the subjects they teach, and
students with disabilities make better progress
when their teachers have specialized skills in
educating these students.
Most, although not all, ASDB teachers are highly
qualified in the subjects they teach, according to
ASDB. An Arizona Department of Education report
shows that approximately 10 percent of ASDB’s
teachers were not highly qualified in hearing-impaired
or visually-impaired special education
and/or in one or more of the subjects they taught
during at least part of the 2011-2012 school year.1
ASDB officials reported that the teachers who do
not meet the requirements are working toward
1 ASDB reports its teachers’ status to the Arizona Department of Education on October 1 each year, and according to ASDB,
updates the database occasionally throughout the year. As of May 7, 2012, the database showed that ASDB had 20
teachers out of the 213 listed who were not highly qualified in hearing-impaired or visually-impaired special education and/
or one or more of the subjects they were teaching. Because ASDB does not review and completely update the database
until closer to October 1, the number of teachers who were not highly qualified as of May 7, 2012, is likely higher or lower
than 20.
page 21
Office of the Auditor General
Highly Qualified Teachers—To be deemed highly
qualified, teachers must have a bachelor’s degree
and full state certification or licensure, and
demonstrate competency in each subject taught.
Demonstration of Competency—Teachers can
demonstrate subject competency with a major in the
subject, credits equivalent to a major in the subject,
passage of a state-developed test; a combination of
teaching experience, professional development, and
knowledge in the subject garnered over time in the
profession; an advanced certification from the state;
or a graduate degree.
No Child Left Behind Act Requirements—The No
Child Left Behind Act requires that teachers teaching
in core academic subjects in public elementary and
secondary school are highly qualified.
Individuals with Disabilities Education Act
Requirements—The Individuals with Disabilities
Education Act requires each person employed as a
public school special education teacher to be highly
qualified as a special education teacher.
Core academic subjects—English, reading or
language arts, mathematics, science, foreign
languages, civics and government, economics, arts,
history, and geography.
Source: U.S. Department of Education’s Individuals with Disabilities
Education Act Web site.
certification through professional development plans. According to ASDB,
many of these teachers are responsible for teaching multiple subjects, but
may be highly qualified in only one core subject.
According to ASDB staff, acquiring and retaining highly qualified staff is
difficult for many reasons, including a lack of competitive pay and the
challenges associated with obtaining the required certifications. Officials at
other deaf and blind schools and ASDB officials identified three possible ways
that deaf and blind schools can improve their ability to ensure that its students
are taught by highly qualified staff. The first way, used by a private school for
the blind in Massachusetts—offering tuition reimbursement and free room
and board to teachers while they work to become highly qualified—may not
be available to ASDB. The second way, increasing the pool of qualified
teachers in the State, which was suggested by a practice in Missouri, is
already under way in Arizona. Specifically, ASDB is working with the University
of Arizona and reported that it is also working with the Arizona Department of
Education to increase the number of hearing-impaired and visually-impaired
special education teachers in the State. ASDB is working with a University of
Arizona masters-level program that is intended to address the shortage of
highly qualified teachers needed to serve students who are deaf or hard-of-hearing
in Arizona, the Southwest, and the nation. The federally funded
program offers online, full- or part-time courses, and its objective is to
graduate 30 teachers who will be eligible for certification in the State of
Arizona.
A third approach used in Florida may offer additional potential for ASDB to
better ensure that its students take classes from highly qualified teachers.
Specifically, the Florida School for the Deaf and the Blind offers its students
the opportunity to take off-campus classes online. Experts have noted that
Web-based courses can make courses available to students without having
to employ highly qualified full-time teachers in each subject in each school,
and that states are choosing to implement online programs for special
education students in order to provide highly qualified teachers in subjects
where highly qualified teachers may be lacking.1 According to ASDB officials,
they are considering using online education classes to offer ASDB students
an opportunity to learn from highly qualified subject matter experts, with local
assistance from teachers who are highly qualified to teach sensory impaired
students. In fact, ASDB tentatively plans to enroll two Arizona School for the
Deaf students in math classes at an Arizona online charter school in the 2012-
2013 school year. ASDB should continue to seek opportunities, such as
alternative delivery classes, to increase its students’ access to highly qualified
teachers.
1 Thomas, W.R. (2002). Funding web-based courses for K-12 students to meet state educational goals. Atlanta, GA:
Southern Regional Education Board, and Muller, E. (2009). Serving students with disabilities in a state-level virtual K-12
public school programs. Alexandria, VA: National Association of State Directors of Special Education, Inc.
page 22
State of Arizona
ASDB is working with a
University of Arizona
masters-level program
intended to address the
shortage of highly
qualified teachers needed
to serve students who are
deaf or hard-of-hearing.
• Post-graduation tracking can help determine student progress and identify
areas that need improvement—Although ASDB has information about
students’ status 1 year after graduation, according to ASDB staff, it does not
compile or analyze the information and use it to improve its programs. Officials
at one state’s deaf and blind schools and a private school stated that tracking
students after graduation is necessary to identify areas in the curriculum that
could use improvement. For example, a state school for the deaf collected
information from its high school graduates to help determine why so many
students were dropping out of post-secondary education programs. The
information gathered indicated students did not feel prepared for dormitory life.
This enabled the school to restructure its high school program so seniors now
live in a dormitory setting that allows students to focus on living skills that are
required to succeed in college.
Similarly, ASDB could use the information collected from recent graduates to
improve its programs. Some comments received from seven students and
families who responded to auditors’ survey of 2011 ASDB graduates suggest
ways ASDB can consider modifying its programs. Specifically:
◦ Providing additional homework help;
◦ Offering group living to facilitate life skills development;
◦ Increasing opportunities to gain work and volunteer experiences; and
◦ Introducing vocational programs earlier.
ASDB should use the results of its surveys of students after graduation to
measure student progress and to identify and implement enhancements to its
students’ educational programs.
• Studying differences in test scores can help narrow achievement gaps—
The No Child left Behind Act requires that all public schools in every state work
towards narrowing achievement gaps in the state as measured by each state’s
standardized test, which in Arizona is AIMS. Studying differences in AIMS
passing rates across ASDB locations may hold some immediate assessment
benefits for ASDB. AIMS test results varied between ASDB’s on-campus
students and students receiving services from ASDB’s regional cooperatives
and among the regional cooperatives. At ASDB’s three campus schools, 74 to
94 percent of students’ spring math and reading scores fell below standards.
According to ASDB officials, on-campus students have higher needs because
of their disabilities, which may contribute to lower test scores. For example,
some students have secondary physical disabilities that cause absences from
school or learning disabilities that cause additional delays in development.
However, failure rates also varied between the five regional cooperatives.
Students at four of the five regional cooperatives passed AIMS at a higher rate
page 23
Office of the Auditor General
AIMS test results varied
between ASDB’s
on-campus students and
students receiving
services from ASDB’s
regional cooperatives and
among the regional
cooperatives.
than the on-campus students. For example, only 49 percent of the Eastern
Highlands regional cooperative students failed the reading test, compared to
77 percent of students in the Southwest regional cooperative where results
were more similar to results for the on-campus students. Examining these
variances more closely may help ASDB officials determine if teaching
practices vary among locations and whether higher scores in some regions
reflect more effective practices that should be implemented across all
locations.
To increase student achievement at all the regional cooperatives and on-site
campuses, ASDB should determine the reasons for variations in test scores
and identify potential solutions to improve test results, and establish
expectations that each campus and regional cooperative will implement best
practices to improve test performance.
Recommendations:
1.1 To help ensure that children with sensory impairments receive needed services,
ASDB should improve its early intervention program by continuing to take the
following steps:
a. Coordinating with other state agencies that are part of the AzEIP program
to establish contract early intervention services throughout the State;
b. Working with the Arizona Department of Education and the Department of
Economic Security to establish guidelines for the use of services provided
to children when they transition out of the AzEIP program and into schools;
c. Providing staff training to ensure that all staff use a consistent curriculum
for early intervention services and that staff accurately reflect delays in
starting services in ASDB’s database;
d. Ensuring that its early intervention program staff have Standards of
Practice certifications as required by the AzEIP program;
e. Revising the early intervention staff job descriptions to ensure they
accurately reflect the services ASDB provides to children and their
families;
f. Providing more detailed information to the public about resources
available through the AzEIP program, as well as descriptions of all the
programs provided by ASDB, including early intervention, preschool, and
school-age programs through its newly developed Web site;
page 24
State of Arizona
page 25
Office of the Auditor General
g. Using other outreach mechanisms, including social networking sites such
as Facebook, YouTube, and Twitter, to reach more families who might
benefit from its services;
h. Working with the Arizona Department of Health Services’ Early Hearing
Detection and Intervention program to develop a new system that will allow
ASDB staff access to infant screening records so they can help ensure any
child who fails a screening receives appropriate assessments and other
services in a timely manner; and
i. Addressing areas identified in the Department of Economic Security’s
review of ASDB’s compliance with state-wide AzEIP requirements.
Specifically, ASDB should:
◦ Provide accurate and timely monthly service data to the Department of
Economic Security;
◦ Improve staff data entry practices and establish procedures that will
help ensure the accuracy of data in ASDB’s database and the monthly
service reports that are generated from the database;
◦ Ensure that Individualized Family Service Plans contain appropriate
and measurable goals as required by the AzEIP program; and
◦ Encourage families to complete and return early intervention surveys.
1.2 ASDB should continue to seek opportunities, such as alternative delivery classes,
to increase its students’ access to highly qualified teachers.
1.3 ASDB should establish a process for compiling, analyzing, and using information
obtained from surveys about its students after graduation to measure student
progress, and to identify and implement enhancements to its students’
educational programs.
1.4 To narrow the achievement gaps and increase the AIMS passing rate among its
students, ASDB should:
a. Determine the reasons for variations in test scores and identify potential
ways to improve test results at the campuses and the regional cooperatives;
and
b. Establish expectations that each campus and regional cooperative will
implement best practices to improve test performance.
page 26
State of Arizona
ASDB should examine regional cooperative
program service fees and strengthen
program operations
FINDING 2
page 27
ASDB provides services to students at local school
districts through its regional cooperative program
As authorized by the Legislature, ASDB established a regional cooperative
pilot program and started providing services in 1988, and continues to operate
five regional cooperatives throughout the State (see Figure 1, page 4). The
intent of this program was to enable local school districts to serve deaf, hard-of-
hearing, and visually-impaired students in a cost-effective way by providing
access to a pool of specially trained personnel and equipment provided by
ASDB (see textbox). Regional cooperative staff travel to the participating
school districts and provide services to students as they remain at the schools
in their districts.
Each regional cooperative has a director who supervises operations and
various staff, including teachers, interpreters, other specialists, and
administrative staff who work with the member districts’ sensory-impaired
students. Regional cooperative teachers consult with school staff, classroom
teachers, parents, and students; provide specialized direct instruction to
students in their areas of need; prepare curricular modifications and
demonstrate techniques for working with individual students; and assist in
student placement by serving as members of the team that develops each
The Arizona State Schools
for the Deaf and the Blind
(ASDB) should take several
steps to improve the
operation of its regional
cooperative program,
including more fully
recovering program costs
and strengthening the
oversight and management
of the program. ASDB’s
regional cooperative
program serves as a
resource for school districts
by providing staff and
equipment to sensory-impaired
students in
member districts. However,
some fees charged by the
five individual regional
cooperatives are
inconsistent, and even for
the fees that are
consistently applied across
all cooperatives, ASDB has
no method to determine
whether the fees cover the
cost of the services
provided. In addition to
developing a structured
approach to review and
establish appropriate fees,
ASDB needs to review the
regional cooperatives’
advisory councils’ role in
fee-setting. Additionally,
ASDB should develop a
consistent way for regional
cooperatives to keep track
of student needs and staff
availability, as well as
equipment provided for
students’ use.
Office of the Auditor General
Overview of the regional cooperative pilot program
• Provide educational programs and related services to all
sensory impaired students if the school participates in
cooperative program and cannot provide an appropriate
placement for the student within the district.
• Provide supplemental services such as audiological and
vision assessments, specialized curriculum materials and
equipment, and district staff development assistance.
• Costs to be paid by participating schools.
• Locations decided by ASDB in consultation with districts.
• Each cooperative advised by committee, including parents,
districts, and local private service organizations.
Source: Auditor General staff summary of Laws 1987, Ch. 363, §19.
student’s Individualized Education Program (IEP) (see textbox, page 11). Each
regional cooperative also has an advisory council that provides advice on the
administration of the cooperative.
About half of Arizona’s school districts participate in the regional cooperative
program. School districts and other public schools, such as charter schools and
Bureau of Indian Affairs (BIA) community schools, must sign agreements with ASDB
if they elect to receive educational services for their deaf, hard-of-hearing, and
visually-impaired students through the regional cooperatives. In the 2011-2012
school year, 114 school districts and 33 other entities participated in the regional
cooperatives. In the 2011-2012 school year, the regional cooperatives served 1,190
students in these districts. According to a representative from a participating school
district, it benefits the district to participate in the regional cooperative because of the
costs the district would incur to obtain the services for its students elsewhere. Many
of the 116 districts in the State that did not participate in the regional cooperatives fell
into two groups: (1) large districts such as the Mesa, Chandler, and Tucson districts,
which use their own staff to provide these services, and (2) very small districts that
do not have any sensory-impaired students.
The regional cooperatives receive monies from various funding sources to pay for
the services provided to the students in the program. Funding sources for services
provided to students by ASDB’s regional cooperatives include the following:
• State General Fund appropriations—ASDB receives an annual appropriation
from the State General Fund for the regional cooperative program. In fiscal year
2013, the appropriation for the program was $803,500. According to ASDB staff,
ASDB uses these appropriations to cover its administrative costs for the regional
cooperatives, such as office rent, utilities, and administrative staff salaries and
employee-related expenses.
• School district membership fees—Each participating school district pays a
per-district membership fee to belong to a regional cooperative. The membership
fees are used to provide services that are not tied to a particular child’s IEP and
include assistance with screening and identification of children, evaluation of
children, and training of school staff.
• Special education vouchers—ASDB receives voucher monies from the
Arizona Department of Education for many of the regional cooperative students
it serves. Generally, ASDB receives voucher monies for students whose primary
disability is a hearing or vision impairment, while districts receive voucher
monies for students with multiple disabilities (see textbox, page 3, for the
definition of multiple disabilities). ASDB and districts work together to decide
which entity will receive the voucher monies. The amount of the educational
voucher is determined by statute, and as of the 2011-2012 school year, the
education voucher was $19,122 for visually-impaired students and $19,008 for
deaf and hard-of-hearing students. If ASDB receives voucher monies for a
page 28
State of Arizona
In the 2011-2012 school
year, 114 school districts
and 33 other entities
participated in the regional
cooperatives.
student, ASDB pays an amount to the district to reimburse the district for services
the district provides to the student such as transportation and any educational
services not provided by the regional cooperative.
• Fees for services—When a district rather than ASDB receives the Arizona
Department of Education voucher payment, it pays ASDB a fee for the services
ASDB provides. These services include ongoing assessment, instruction,
provision of equipment, and vocation counseling. The costs for services under the
fee-for-service structure depend on the number of hours of service provided. As
shown in Table 3 (see page 30) the levels of service, types of service, and annual
fee-for-service charges are uniform among all the cooperatives. For example,
districts pay $5,245 per year for a student who receives 1.5 hours of services per
week, and $21,500 per year for a student who receives 10 to 15 hours of services
on a weekly basis.
• Additional fees—ASDB receives additional monies from districts for services that
exceed what is outlined in the membership fees or fee-for-service amount. For
example, one regional cooperative’s membership fee for districts with less than
200 students covers 26 audiological assessments. If the number of assessments
exceeds 26, the cooperative charges $20 for each additional audiological
assessment.
ASDB should examine fees for regional cooperative
program services
ASDB should systematically examine the various fees that regional cooperatives
charge, make them more consistent, and ensure that they cover the costs of the
services provided. Although fee-for-service amounts and services are consistent state-wide,
many other fees or payments, such as membership fees paid by participating
districts and reimbursements paid to districts for transportation and other services, are
not consistent across regions. These inconsistencies create inequities in which some
districts’ payments subsidize other districts’ expenses. Further, ASDB has not
determined if the fees paid by districts for services provided by regional cooperative
staff cover the costs of the services. To resolve these issues, ASDB needs to develop
and implement a structured approach for determining appropriate fees and payments.
Membership and supplemental fees charged to districts and payments
to districts are inconsistent—ASDB has not established policies or
procedures for determining appropriate membership and supplemental fees for
school districts that participate in regional cooperatives or for determining the
amounts that the regional cooperatives should pay to reimburse district schools for
services provided to students for whom ASDB receives voucher monies. Instead,
each regional cooperative has developed its own membership fee and list of
services included in the membership fee. In addition, some have established
page 29
Office of the Auditor General
Each regional cooperative
has developed its own
membership fee and list
of services included in the
membership fee.
page 30
State of Arizona
1 The rates for BIA community schools are set by a separate process.
2 According to a regional cooperative official, a teacher typically provides an itinerant level service a couple of
times a week and the student receives visually-impaired or hearing-impaired services that complement the
district teacher’s teaching curriculum.
3 According to a regional cooperative official, a teacher provides a resource level service on a daily basis. The
student might receive some services from the district teacher.
Source: Auditor General staff compiled information from ASDB’s regional cooperatives.
Table 3: Services Provided by Regional Cooperative Staff
School Year 2011-2012
Service Level Type of Service Hours of Service
Service
per Year1
Consult indirect
Limited direct service 1 hour a month and
no equipment
provided
$2,800
Consult direct
Ongoing assessment and limited service 1 hour a month and
no equipment
provided
2,800
Level I itinerant2
Ongoing assessment, specialized and direct
instruction, provision of equipment, vocational
counseling, and direct service to student in
amplification use and listening skill training.
1.5 hours a week 5,245
Level II itinerant2
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary,
speech development, math, science, and
social studies. Direct service to student in
amplification use, listening skill training, and
sign language instruction.
1.5-3 hours a week
7,335
Level III resource3
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary,
speech development, math, science, and
social studies. Direct services to student in
amplification use, listening skill training, and
sign language instruction.
3-5 hours a week 11,000
Level IV resource3
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary and
speech development, math, science, and
social studies. Direct services to student in
amplification use, listening skill training, sign
language instruction, sign language
interpreting and note taking, and classroom
tutor or instructional aide.
5-10 hours a week 16,260
Level V resource3
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary and
speech development, math, science, and
social studies. Direct services to student in
amplification use, listening skill training, sign
language instruction, sign language
interpreting and note taking, and classroom
tutor or instructional aide.
10-15 hours a week
21,500
additional supplemental fees. Further, each regional cooperative has determined an
amount it reimburses to districts for services the districts provide to students for
whom ASDB receives Arizona Department of Education voucher monies even
though the voucher amount is the same regardless of which district or cooperative
the student comes from. The resulting amounts vary, and the regional cooperatives
explained that the differences have historically existed. Specifically:
• Membership fees differ among regions—The regional cooperatives use
different tiers for grouping districts and setting membership fees based on
student population within the district (see Table 4). For example, the Southwest
regional cooperative has three tiers—districts with less than 500 students, 501
to 2,000 students, and more than
2,000 students, with different fees for
each tier. However, the Eastern
Highlands regional cooperative has
five tiers ranging from under 200
students to 5,000 or more students,
again with different fees for each tier.
Additionally, as shown in Table 4, the
range of membership fees charged
by each regional cooperative for their
various tiers differs for each regional
cooperative. For example, the fees for
the tier comprising the regional
cooperative’s smallest districts
ranged from $240 to $500 in 2011-
2012.
• Services covered by membership fees differ among cooperatives, and
some cooperatives charge supplemental fees for services, while others do
not—The services covered by the membership fees also differ from region to
region. As a result, some regional cooperatives charge additional fees for
supplemental services that some regional cooperatives include in the set of
services covered by the membership fees. For example, although most regional
cooperatives include district staff training in the membership fees, one regional
cooperative charges a separate fee of $25 per person to train district staff in
conducting hearing screenings. Another regional cooperative has additional
charges for certain services if they are provided to fee-for-service students—$71
per hour for mobility and orientation training and $45 per hour for interpreter
services. The other three cooperatives have not established similar additional
charges and instead provide these types of services with no additional charges.
• Reimbursements to districts inconsistent and not based on actual services
provided by districts—As previously mentioned, ASDB receives voucher
monies for students whose primary disability is a hearing or vision impairment
and for whom ASDB assumes the primary educational responsibility within
page 31
Office of the Auditor General
Table 4: Regional Cooperative Membership Fee Structure
School Year 2011-2012
1 Bureau of Indian Affairs community schools.
Source: Auditor General staff analysis of data received from ASDB’s regional
cooperatives.
Membership fees and supplemental fees differ among regions—
Regional
Cooperative
Number of
Tiers Membership Fee
Southeast 4 $260 up to $820
Desert Valleys 5 $280 up to $1,000
North Central
BIA Schools1
4
5
$240 up to $720
$280 up to $1,000
Eastern Highlands 5 $280 up to $1,000
Southwest 3 $500 up to $1,250
these students’ home school districts. If ASDB receives voucher
monies for a student, ASDB reimburses the district for services
the district provides to the student such as transportation and
any educational services not provided by the regional
cooperative. However, the regional cooperatives have set
differing reimbursement amounts, even though the voucher
amount is the same regardless of which district or cooperative
the student comes from. As shown in Table 5, the per-student
amounts range from no reimbursement for students in the
southeast region who are receiving specified services from the
regional cooperative to $3,500 annually for all students in two
regions and for some students in a third region.
The cumulative result of these inconsistencies can be substantial.
Table 6 (see page 33) shows examples of the differences that
can result, both for voucher students—those students for whom
ASDB receives the Arizona Department of Education voucher—
and for those students for whom the district receives the
voucher. For a visually-impaired voucher student, regional
cooperative 1 receives a membership fee of $260 and reimburses
the district $2,000, while regional cooperative 2 receives a
membership fee of $500 and reimburses the district $3,500. As
a result, regional cooperative 1 has $17,382 to cover the
students’ costs, while regional cooperative 2 has $16,122 to
cover the students’ costs, which is a difference of $1,260. For
fee-for-service students, the difference is less—$240—because
it relates only to the membership fee. As a result, the regional
cooperatives can have a different amount of monies per student
to cover the same services.
ASDB unable to determine if fees are adequate to cover costs—
ASDB policy requires its regional cooperatives’ advisory councils to recommend
a fee structure that will cover all costs of services that are not covered by legislative
appropriations. However, ASDB has not evaluated whether the membership fees
and fee-for-service amounts cover the costs of the services provided to regional
cooperative students. Although ASDB does not have records of past fees, officials
at three regional cooperatives reported that fees had not been changed since at
least 2007, and a fourth regional cooperative official said fees had not been
changed since before 1997. The fifth regional cooperative official reported that
fees had not changed since before 1992. Additionally, in fiscal year 2011, the
ASDB Cooperative Services Fund’s fund balance decreased, suggesting the fee
amounts may be inadequate to cover costs. Two regional cooperatives prepare a
report that shows some of the revenues and expenses associated with a district’s
students if the district requests the report. However, because this report does not
include all revenues and expenses and is prepared by only two of the five regional
cooperatives, ASDB cannot rely on it to determine whether its fees are adequate.
page 32
State of Arizona
Table 5: Regional Cooperative
Reimbursements to Districts
School Year 2011-2012
1 Without educational interpreter, instructional assistant,
orientation and mobility, and rehabilitation therapy.
2 With educational interpreter, instructional assistance,
orientation and mobility, rehabilitation therapy, and
educational transcriber.
3 If the student receives services involving two or more staff.
4 If a full-time sign interpreter or instructional assistant is
assigned to the regular education classroom.
Source: Auditor General staff compiled information from
ASDB’s regional cooperatives.
Regional Cooperative Reimbursement Amounts
Per Voucher Student
Southeast $2,0001
or
$02
Desert Valleys $3,500
North Central $2,700
or
$1,5003
Eastern Highlands $3,500
Southwest $3,500
or
$1,5004
ASDB has not evaluated
whether the membership
fees and fee-for-service
amounts cover the costs
of the services provided to
regional cooperative
students.
page 33
Office of the Auditor General
Although regional cooperatives independently establish their fees, ASDB combines
the revenues to pay regional cooperatives’ costs throughout the State. For example,
at the end of fiscal year 2011, the North Central regional cooperative’s portion of the
ASDB Cooperative Services Fund’s fund balance was negative $129,118, while the
Desert Valleys regional cooperative’s portion was more than $2.5 million. ASDB
used monies from the Desert Valleys regional cooperative to purchase 29 cars for
all of the regional cooperatives and to pay for a conference attended by all regional
cooperative staff. In effect, Desert Valleys regional cooperative member school
districts were subsidizing other regional cooperatives’ expenses.
ASDB needs to adopt structured approach to establishing fees—To
address the problems regarding inconsistencies in some fees and to determine
whether its fees cover the cost of services provided, ASDB needs to adopt a
structured fee-setting approach. A structured approach would allow ASDB to
evaluate current fees and propose new fees that would (1) fully cover costs related
to the services provided by the regional cooperatives and (2) ensure that specific
fees are appropriate for the services.
Mississippi’s Joint Legislative Committee on Performance Evaluation and Expenditure
Review (PEER) developed an approach for evaluating and setting fees that may
assist ASDB.1 PEER’s approach consists of a decision model for establishing or
increasing government fees, called the Theory of Fee Setting in Government, as well
1 Joint Legislative Committee on Performance Evaluation and Expenditure Review. (2002). State agency fees: FY 2001
collections and potential new fee revenues. Jackson, MS: Author.
Source: Auditor General staff compiled information from ASDB’s regional cooperatives.
Table 6: Example of Differences in Regional Cooperative Service Costs
School Year 2011-2012
Voucher Students
Regional Cooperative 1
Regional Cooperative 2
Difference
Membership fee
$ 260
$ 500 $ 240
Voucher 19,122 19,122 0
Reimbursement to
district
(2,000)
(3,500) (1,500)
Total per student
$17,382
$16,122 $1,260
Fee-For-Service
Students
Regional Cooperative 1
Regional Cooperative 2 Difference
Membership fee
$ 260
$ 500 $240
Level II itinerant
5,245
5,245 0
Total per student
$ 5,505
$5,745
$ 240
Although regional
cooperatives independently
establish their fees, ASDB
combines the revenues to
pay regional cooperatives’
costs throughout the State.
page 34
State of Arizona
as guidance on implementing new fees.1 Figure 3 (see page 35) summarizes key
concepts from PEER’s approach.
ASDB’s approach should include the following:
• Assessing efficiency of operations—ASDB should assess the efficiency of its
operations to ensure costs are as low as possible and document the results of
its assessment. As ASDB assesses the efficiency of its operations, it should
seek to minimize costs where possible.
• Developing a cost-accounting method—ASDB should determine whether to
consider costs independently for each regional cooperative or in combination
on a state-wide basis, and then develop and finalize a method for tracking and
allocating relevant service and equipment costs.
• Developing fees based on relevant costs—To help ensure fees are
appropriate and equitable, ASDB should identify the actual costs for specific
services for which fees are charged. In addition, fees should take into account
factors that affect the cost of the specific service. For example, some regional
cooperatives may incur more costs for transportation because these regional
cooperatives must transport staff and/or equipment greater distances to reach
the districts they serve.
Once developed, ASDB should use this approach to assess its fees and establish
new fees. If the new fees are substantially higher than existing fees, ASDB should
consider phasing in the increases over time. In addition, ASDB should develop and
implement policies and procedures for using the method to establish new fees.
ASDB should also develop a systematic way to determine whether and how much
to pay school districts for services provided to students for whom ASDB receives
Arizona Department of Education voucher monies. ASDB is not statutorily required
to pay the districts, but it has historically chosen to reimburse the districts for
transportation and other services. If ASDB continues its practice of reimbursing
districts, it should develop a process to determine the appropriate amount of these
reimbursements.
Regional councils’ role in fee-setting needs review
As ASDB develops a structured approach to setting fees, it also needs to examine
the fee-setting role played by the regional cooperatives’ advisory councils. Each
regional cooperative has an advisory council comprising representatives from
1 According to PEER, the approach was based on a review of academic literature, economics theory, and policies and
procedures from various states and the United States and Canadian governments.
If ASDB continues its
practice of reimbursing
school districts, it should
develop a process to
determine the appropriate
amount of these
reimbursements.
page 35
Office of the Auditor General
Figure 3: Mississippi Joint Legislative PEER Committee’s
Structured Fee-Setting Process
Developed for State Government
Source: Auditor General staff analysis of fee-setting model.
Determine whether fees or taxes should fund the service
Who benefits from the service: individuals, the public, or both?
􀁸􇡆 Fees should finance services that benefit individuals.
􀁸􇡔 Taxes should finance services that benefit the public.
􀁸􇡗 When both individuals and the public benefit from a service, financing can come
from both fees and taxes.
Identify and analyze legal issues
􀁸􇡁 Are fees limited by statute? If so, is legislation required to change them?
􀁸􇡓 Should administrative rules be revised?
Identify the fees’ purpose
􀁸􇡓 Should fees cover the cost of providing the service?
􀁸􇡓 Should fees be set to influence behavior?
􀁸􇡓 Should fees be set to encourage compliance with program regulation and goals?
Assess factors influencing fee amount
􀁸􇡗 What effect will fees have on those who pay them?
􀁸􇡗 What effect will fees have on annual revenue?
􀁸􇡗 What do similar states charge for the service?
􀁸􇡗 Will the public accept the fees’ necessity?
􀁸􇡉 Is the Department subsidizing other government operations?
Determine appropriate methodology for setting fees
􀁸􇡄 Determine if there is a comprehensive cost accounting system.
􀁸􇡓 Seek to reduce costs as much as possible.
􀁸􇡍 Measure direct and indirect costs of the time staff spends in service activities.
􀁸􇡄 Determine economic impact on regulated entities.
Implement fees
􀁸􇡏 Obtain amended legislation and regulation as needed.
􀁸􇡐 Prepare those who pay fees for changes by providing advanced notice and
explaining the purpose and reasoning of new fees.
􀁸􇡔 Train staff to answer questions regarding the new fees.
Periodically assess revenue, costs, and program outcomes to
update fee amounts
page 36
State of Arizona
participating public schools and ASDB staff. These councils have taken on the
responsibility of approving membership fees and reimbursement amounts.
Although neither statute nor ASDB policy requires an advisory council vote to
increase a regional cooperative’s membership fee or propose other changes in
reimbursement amounts, at least four of the regional cooperatives rely on the council
members’ vote to do so. The regional cooperatives hold annual or more frequent
meetings with their respective advisory councils. During these meetings, regional
cooperative staff inform council members of the regional cooperative budget, the
number of participating member districts, and any other important information
affecting the operations of the regional cooperative.
For two reasons, setting fees appears to be an inappropriate role for the advisory
councils. First, it goes beyond the role for these councils established in ASDB policy.
Under ASDB policy, the councils’ duties include making recommendations about
membership fees, but not actually setting them. By allowing the councils to determine
fees instead of providing recommendations for ASDB management to consider,
regional cooperative staff appear to have misinterpreted the advisory council’s
responsibilities. Second, in the kind of structured fee-setting approach discussed
earlier, the information needed to set appropriate fees would be most fully available
to management, and not the advisory councils. ASDB should modify its policy to
remove the provision that advisory councils will recommend a membership fee
structure.
Additionally, ASDB should determine whether to continue with advisory councils for
each regional cooperative or if it would be more appropriate to establish a single
advisory council for all of the regional cooperatives. There is no statutory or regulatory
requirement for the regional cooperatives to have advisory councils. Instead, the
advisory councils have evolved over time from earlier requirements outlined in the
regional cooperative pilot program legislation, which is no longer in place. Specifically,
when the regional cooperative pilot program was introduced in 1987, legislation
required ASDB to establish an advisory committee for each cooperative to provide
advice on the administration of the cooperative. The advisory committee included
parents, representatives from local private organizations that provide services to the
sensory impaired, and representatives of participating school districts. Current
regional advisory councils do not include parents or representatives of local private
service organizations.
The administrative duties outlined in ASDB policy regarding advisory councils could
be addressed by a state-wide council that includes representatives of participating
districts throughout the State and could also include parents and representatives of
private service organizations. Alternatively, ASDB could consider retaining the
regional advisory councils but include parents and service organization representatives,
similar to the way the councils were envisioned in the pilot program legislation. ASDB
should determine and implement the appropriate structure for the advisory councils.
Regardless of how the advisory councils are structured, ASDB management needs
ASDB should determine
whether to continue with
advisory councils for each
regional cooperative or if it
would be more appropriate
to establish a single
advisory council for all of
the regional cooperatives.
page 37
Office of the Auditor General
to provide oversight to ensure council authority in practice does not exceed the
advisory role outlined in ASDB policy.
Regional cooperatives are not consistent in tracking
resources
Regional cooperatives do not use the same systems to track resources, meaning that
students potentially may not receive the resources they need. Specifically:
• Education staff services—The regional cooperatives use different systems to
keep track of student needs, such as the need for an educational interpreter, and
the availability of educational staff such as interpreters, teachers, and therapists.
Each regional cooperative uses either a computer program such as Microsoft
Access or hard copy forms to manage its student caseload.
• Equipment inventory—The regional cooperatives use different systems to track
and manage the educational equipment provided to the students in local school
districts, such as braille writers and educational books. Some regional cooperatives
use a hard copy inventory tracking system, and others do not use an inventory
tracking system at all. Additionally, ASDB lacks a state-wide inventory system to
track equipment owned by all of its regional cooperatives.
Consistent tracking could help ensure that students have access to all the educational
services and equipment they need. For example:
• Providing resources when students move across cooperatives—Regional
cooperative officials reported that students move from one cooperative to another,
and because the regional cooperatives do not use the same computer programs
to track educational services, it can be hard to transfer the services to the
student’s new school.
• Identifying underused resources—Because there is no state-wide inventory of
equipment resources, some regional cooperative officials reported that they
informally call one another if they need equipment that might not be in use by
another regional cooperative. Without a state-wide inventory, equipment could be
going unused in one region that could benefit students in other regions.
• Training staff—Regional cooperative officials also stated that a single computer
program used by all regional cooperatives would make it easier to train staff and
IT support staff on how to use the program to track these services.
ASDB could use systems it has developed or is developing for other programs to
better track and manage educational services and equipment in the regional
cooperatives. Specifically:
ASDB lacks a state-wide
inventory system to track
equipment owned by all of
its regional cooperatives.
page 38
State of Arizona
• ASDB is developing an in-house computer program to track and manage the
schedules of the education services in the birth to 3 program discussed in
Finding 1 (see pages 9 though 25). This program administers these services
throughout the State. Once developed and tested, the regional cooperatives
should use this program to track and manage the educational services that are
provided to students by the regional cooperatives.
• As of January 2012, ASDB purchased and implemented an inventory system to
track on-campus assets. The regional cooperatives should use this same
system to track and manage the inventory of the equipment provided to the
students in the regional cooperatives.
Recommendations:
2.1 To ensure its fees more fully reflect its costs, ASDB should develop a structured
approach to evaluate current fees and implement new fees that would cover all
costs related to the services provided by the regional cooperatives that are not
covered by legislative appropriations, and ensure that specific fees are
appropriate for the services. In developing this approach, ASDB should do the
following:
a. Assess the efficiency of its operations to ensure costs are as low as
possible and document the results of its assessment. As ASDB assesses
the efficiency of its operations, it should continue seeking to minimize
costs where possible;
b. Determine whether to consider costs independently for each regional
cooperative or in combination on a state-wide basis, and develop and
implement a method for tracking and allocating relevant ASDB costs;
c. Identify the actual costs for specific fees, including membership fees, fee-for-
service costs, and additional supplemental service costs to help
ensure fees are appropriate and equitable. In addition, fees should take
into account factors that affect the cost of the specific service; and
d. Develop and implement policies and procedures for using the method to
develop appropriate fees.
2.2 ASDB should develop a systematic way to determine whether and how much
to pay school districts for services the districts provide to students for whom
ASDB receives Arizona Department of Education voucher monies.
page 39
Office of the Auditor General
2.3 ASDB should provide more oversight to ensure that advisory councils play an
appropriate role in the regional cooperative program by:
a. Modifying its policy to remove the provision that advisory councils will
recommend a fee structure;
b. Determining and implementing the appropriate structure for the advisory
councils, such as a single state-wide advisory council composed of
participating school district representatives and parents and representatives
of local private service organizations, or regional advisory councils that
include parents and local private service organization representatives; and
c. Ensuring that its councils adhere to the advisory role and responsibilities
outlined in ASDB policy.
2.4 ASDB should establish a single, consistent system for managing and tracking
regional cooperative resources by:
a. Expanding the use of ASDB’s in-house computer program for tracking and
managing birth to 3 program educational services, once the program has
been developed and tested, to track and manage educational services
provided to students in the regional cooperatives; and
b. Using ASDB’s inventory system for on-campus assets to track and manage
the inventory of equipment provided to students in the regional cooperatives.
page 40
State of Arizona
ASDB needs to improve its information
technology practices
FINDING 3
page 41
IT systems used extensively and contain sensitive
data
ASDB uses IT systems extensively. In addition to administrative functions such
as payroll and accounting, ASDB’s IT systems track and monitor student
information, including personal and medical information regarding students’
hearing or vision impairments and other disabilities, as well as information
about their educational performance. This type of information is private, and
two federal laws—the Health Insurance Portability and Accountability Act
(HIPAA) and the Family Educational Rights and Privacy Act (FERPA)—require
that such information be protected against unauthorized disclosure. ASDB
also uses IT in the classroom as part of a variety of adaptive teaching and
learning techniques for its students with hearing and vision impairments.
ASDB’s IT department, which consists of nine full-time employees, supports
technology for staff and students across its three campuses and five regional
cooperatives. This support includes administering and supporting user
workstations, servers, assistive and educational technologies, critical business
applications and services, and various other network devices.
ASDB has not addressed critical IT weaknesses
State information security experts and auditors have identified critical
weaknesses in ASDB’s IT environment. These weaknesses have persisted for
several years. In 2009, ASDB engaged ADOA’s Information Security group to
assess ASDB’s information technology environment. The resulting report
identified several gaps between the existing state of ASDB’s IT environment
and best practices and made recommendations for how ASDB should
address the deficiencies. The report also found that ASDB’s IT department had
received little strategic direction or oversight from ASDB management.
Although ASDB has made some efforts to address the weaknesses ADOA
identified, auditors found that critical IT weaknesses still exist. Specifically,
auditors found that ASDB’s IT security controls are weak, its disaster recovery
planning is inadequate, its data backup strategy is flawed, and it has no data
classification process to help ensure that the information it maintains is
sufficiently protected. ASDB officials stated that the IT department lacks the
Although the Arizona State
Schools for the Deaf and
the Blind (ASDB) has made
some improvements to its
information technology (IT)
practices since the Arizona
Department of
Administration (ADOA)
assessed those practices
in 2009, several additional
improvements are needed
to help ensure that student
and school information is
properly safeguarded.
Specifically, auditors found
that continued weaknesses
have led to critical
vulnerabilities in several IT
areas. These include IT
security management,
disaster recovery, and data
backup. ASDB should first
prioritize and then correct
these IT weaknesses to
minimize the impact these
vulnerabilities and security
threats could have on its
operations.
Office of the Auditor General
page 42
State of Arizona
staff and resources necessary to address all of ASDB’s IT issues and needs. As a
consequence, it has not prioritized addressing the recommendations made in
ADOA’s report, which has contributed to the lack of progress in addressing and
resolving weaknesses. In October 2011, the department had turnover in a key
position when ASDB’s IT Director left. At that time, the existing IT security specialist
was made the interim IT Director but also retained his responsibilities for security. As
of June 2012, ASDB had still not appointed a permanent IT Director.
IT security controls are weak—ASDB’s controls over IT security are weak, and
its systems are susceptible to attack. According to IT standards and best practices,
effective security management helps protect IT assets and minimizes the impact
that security vulnerabilities and incidents could have on IT operations. Security
monitoring is also essential to help ASDB comply with federal laws and regulations
designed to protect sensitive information, financial aid records, and health
information. Despite the critical importance of effective IT security management,
auditors found weaknesses in several key areas, including ASDB’s efforts to
assess risk and monitor its systems, secure its net

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A REPORT
TO THE
ARIZONA LEGISLATURE
Debra K. Davenport
Auditor General
Performance Audit and Sunset Review
Arizona State
Schools for the
Deaf and the Blind
Performance Audit Division
September • 2012
REPORT NO. 12-05
The Auditor General is appointed by the Joint Legislative Audit Committee, a bipartisan committee composed of five senators and five
representatives. Her mission is to provide independent and impartial information and specific recommendations to improve the opera-tions
of state and local government entities. To this end, she provides financial audits and accounting services to the State and political
subdivisions, investigates possible misuse of public monies, and conducts performance audits of school districts, state agencies, and
the programs they administer.
The Joint Legislative Audit Committee
Audit Staff
Copies of the Auditor General’s reports are free.
You may request them by contacting us at:
Office of the Auditor General
2910 N. 44th Street, Suite 410 • Phoenix, AZ 85018 • (602) 553-0333
Additionally, many of our reports can be found in electronic format at:
www.azauditor.gov
Dale Chapman, Director
Shan Hays, Manager and Contact Person
Kori Minckler, Team Leader
Jay Rasband
Beth Rensvold
Richie Rinaldi
Representative Carl Seel, Chair
Representative Tom Chabin
Representative Justin Olson
Representative David Stevens
Representative Anna Tovar
Representative Andy Tobin (ex officio)
Senator Rick Murphy, Vice Chair
Senator Andy Biggs
Senator Rich Crandall
Senator Linda Lopez
Senator David Lujan
Senator Steve Pierce (ex officio)
ASDB uses standardized tests
to assess student progress—
These tests include the state-wide
Arizona’s Instrument to Measure
Standards (AIMS) test as well as
another test similar to the AIMS
called Measures of Academic
Progress (MAP).
Most ASDB students did not
meet standards on AIMS—
ASDB students generally scored
lower on AIMS than did Arizona
students as a whole. Although
some ASDB students passed and
even exceeded standards on the
spring 2011 AIMS, most did not.
MAP results showed students
made some progress but still
testing well below grade level—
ASDB students’ MAP test scores
showed that they start at a much
lower level than national norms. Although
limited growth occurred after 5th and 6th
grades and continued into high school, it
was not sufficient to bring students’ scores
within reach of national norms. For
example, by the 11th grade, ASDB
students scored the same as the average
3rd-grade student would in reading and
scored slightly below the average
4th-grade student in math.
Standardized test scores are limited
indicators of program success—Sensory-impaired
students may have difficulty
taking standardized tests because of
natural disadvantages these students may
face in taking these tests. In addition, there
is little comparative information about
scores attained by similar students in other
Arizona schools or other states’ schools.
ASDB uses common practices, but can
strengthen its practices—To help ensure
success in educating its students, ASDB
2012
September • Report No. 12-05
Arizona State
Schools for the
Deaf and the Blind
Our Conclusion
The Arizona State Schools
for the Deaf and the Blind
(ASDB) serves children and
students from birth through
21 years of age who have
sensory impairments such
as deafness and blindness.
As of April 2012, ASDB had
2,240 students who either
attended one of its three
on-campus schools,
participated in its birth to
age three or preschool
programs, or received ASDB
services at their local
schools. ASDB can do more
to promote student success
by ensuring that children
with sensory impairments
receive services early in their
lives, increasing students’
access to highly qualified
teachers, and researching
and addressing differences
in students’ test scores.
ASDB should also ensure its
regional cooperative
program, which serves
students at their local
schools, more fully recovers
its costs. It should also
strengthen oversight and
management of the
program. Finally, ASDB
needs to address critical
information technology
weaknesses.
REPORT
HIGHLIGHTS
PERFORMANCE AUDIT
ASDB can do more to promote student success
follows commonly used practices,
including using technology to help
students learn. In addition, ASDB groups
students according to their academic
ability rather than age. However, ASDB
can strengthen the following practices:
• Early Intervention—Early interven-tion
services are a critical element in
a student’s success. ASDB provides
early intervention services through a
program called Arizona Early Interven-tion
Program. ASDB has identified
areas where it can do more to improve
this program such as coordinating with
the other agencies involved in the pro-gram,
better organizing and training
staff, and reaching out to families with
sensory-impaired infants and children.
• Highly qualified teachers—Federal
law requires that disabled students
be taught by teachers who are highly
qualified in special education and in
core academic subjects. According
Spring 2011 AIMS Test Results for ASDB Students
and State-wide Students
0
10
20
30
40
50
60
70
Falls Far Below Approaches Meets Exceeds Percent of Students
Reading
ASDB
State-wide
0
10
20
30
40
50
60
Falls Far Below Approaches Meets Exceeds
Percent of Students
Math
ASDB
State-wide
Arizona State
Schools for the
Deaf and the Blind
REPORT
HIGHLIGHTS
PERFORMANCE AUDIT
September 2012 • Report No. 12-05
A copy of the full report is available at:
www.azauditor.gov
Contact person:
Shan Hays (602) 553-0333
to an Arizona Department of Education report,
about 90 percent of ASDB teachers were highly
qualified during the 2011-2012 school year.
According to ASDB officials, it is difficult to hire
and retain highly qualified teachers for many
reasons, including lack of competitive pay and
the challenges of obtaining the required certifi-cations.
ASDB is working with the University of
Arizona and the Arizona Department of Educa-tion
to increase the pool of qualified teachers.
• Studying differences in test scores—Federal
law requires that all public schools work to nar-row
achievements gaps in their states. Study-ing
differences in AIMS passing rates across
the various ASDB locations may help improve
ASDB’s student achievement.
Recommendations—ASDB should:
• Improve its early intervention program to ensure
that children receive needed services.
• Increase students’ access to highly qualified
teachers.
• Study differences in test scores and implement
potential solutions to improve student achieve-ment.
ASDB provides services at local school districts
through its regional cooperative program—ASDB
established a regional cooperative program in 1988
to help local school districts serve sensory impaired
students. There are five regional cooperatives, and
each has a staff of teachers, interpreters, and other
specialists. About one-half of state school districts
participate in the program.
Funding comes from various sources—Funding
for the regional cooperatives comes from special
education vouchers through the Arizona
Department of Education for assessments,
counseling, and direct teaching services; from the
State General Fund for program administrative
costs; and from school district membership fees to
screen children and train school staff.
ASDB should examine fees—Each regional
cooperative has established its own membership
fees it charges to school districts. Districts also pay
ASDB for direct educational services provided to
their sensory impaired students. ASDB does not
have policies for determining appropriate
membership and other fees. Further, ASDB has not
evaluated whether such fees cover the costs of the
services provided.
Recommendation—ASDB should ensure that fees
cover the cost of all services provided by regional
cooperatives by assessing operations, tracking
costs, and developing appropriate fees.
ASDB should review regional cooperative service fees and
strengthen its operations
ASDB needs to improve its information technology practices
In 2009, the Arizona Department of Administration’s
Information Security group assessed ASDB’s infor-mation
technology (IT) environment. This assess-ment
identified deficiencies and made several
recommendations. Although ASDB tried to address
the deficiencies, this audit identified the following IT
security control weaknesses:
• No risk assessment or security reviews of the IT
environment have been done.
• The IT network does not have adequate controls
to secure it from hackers.
• There is no effective process for updating com-puters
and servers, which are running critical
systems on outdated software.
ASDB also does not have a comprehensive disaster
recovery plan and does not properly test or backup
data. As a result, ASDB may not be able to meet
federal and state requirements to protect the privacy
of it students and staff.
Recommendations—ASDB should:
• Strengthen IT security controls.
• Address disaster recovery deficiencies.
• Improve data backup.
TABLE OF CONTENTS
continued
Introduction 1
Finding 1: ASDB can do more to promote student success 9
ASDB aims to prepare students for future 9
ASDB uses several assessments to measure student progress 10
Test scores showed some academic progress, but comparative information
for assessing program success is limited 11
ASDB uses commonly used practices but can work to improve 15
Recommendations 24
Finding 2: ASDB should examine regional cooperative
program service fees and strengthen program operations 27
ASDB provides services to students at local school districts through
its regional cooperative program 27
ASDB should examine fees for regional cooperative programs services 29
Regional councils’ role in fee-setting needs review 34
Regional cooperatives are not consistent in tracking resources 37
Recommendations 38
Finding 3: ASDB needs to improve its information technology
practices 41
IT systems used extensively and contain sensitive data 41
page i
Office of the Auditor General
TABLE OF CONTENTS
continued
ASDB has not addressed critical IT weaknesses 41
Recommendations 47
Sunset Factors 49
Appendix A: Test results a-i
Appendix B: Methodology b-i
Agency Response
Tables
1 Student Enrollment by Type of Disability
School Year 2011-2012 2
2 Schedule of Revenues, Expenditures, and Changes in Fund Balance
Fiscal Years 2009 through 2012
(Unaudited) 7
3 Services Provided by Regional Cooperative Staff
School Year 2011-2012 30
4 Regional Cooperative Membership Fee Structure
School Year 2011-2012 31
5 Regional Cooperative Reimbursements to Districts
School Year 2011-2012 32
6 Example of Differences in Regional Cooperative Service Costs
School Year 2011-2012 33
page ii
State of Arizona
TABLE OF CONTENTS
concluded
Figures
1 Regional Cooperatives, School Districts, and Students Served
As of April 2012 4
2 Spring 2011 AIMS Test Results for ASDB Students and State-wide Students 12
3 Mississippi Joint Legislative PEER Committee’s Structured
Fee-Setting Process Developed for State Government 35
4 Spring 2008, 2009, 2010, and 2011 AIMS Math Test Results
for ASDB Students and State-wide Students a-i
5 Spring 2008, 2009, 2010, and 2011 AIMS Reading Test Results
for ASDB Students and State-wide Students a-i
page iii
Office of the Auditor General
ASDB educates students with sensory
impairments
Programs and responsibilities
ASDB was established in 1912 to provide education to students with sensory
impairments such as deafness or blindness. ASDB enrolled 478 students at its
on-campus schools in the 2011-2012 school year (see Table 1, page 2). In
addition, ASDB provided services to 1,190 additional students in school
districts and 299 preschool students throughout the state during the 2011-
2012 school year.
In accordance with state law, ASDB provides educational programs for chil-dren
and students from birth through 21 years who have a vision and/or hear-ing
loss (see textbox for ASDB’s mission). According to statute, school districts
must arrange for a placement and evaluation team for students with a vision
and/or hearing impairment.
The team includes the child’s
parent or guardian as well as
school district and ASDB rep-resentatives.
This team deter-mines
the appropriate educa-tional
placement for the stu-dent
based on his or her indi-vidualized
education program.
Students can attend a local
school district, charter school,
or one of the ASDB campuses.
As of April 2012, the 1,668 students ASDB served were enrolled in the following
schools and/or programs:
• Arizona Schools for the Deaf and Blind (110 students at the Arizona
School for the Deaf and 85 students at the Arizona School for the
Blind)—Two schools, the Arizona School for the Deaf and the Arizona
School for the Blind, make up the ASDB Tucson campus. According to
ASDB officials, students can live on campus as residential students or
attend as day students if they live within 60 miles of the campus. As of
April 2012, 70 students lived on campus. Both schools are accredited by
page 1
Scope and Objectives
INTRODUCTION
The Office of the Auditor
General has conducted a
performance audit and
sunset review of the
Arizona State Schools for
the Deaf and the Blind
(ASDB) pursuant to an
October 26, 2010,
resolution of the Joint
Legislative Audit
Committee. This audit was
conducted as part of the
sunset review process
prescribed in Arizona
Revised Statutes (A.R.S.)
§41-2951 et seq. This
performance audit and
sunset review addresses
(1) how ASDB can increase
its use of best practices to
promote its students’
success, (2) improvements
that ASDB should make to
the operations of its
regional cooperatives
program, and (3) the need
to better protect student
data and make other
improvements to ASDB’s
information systems
management. The report
also includes responses to
the statutory sunset
factors.
Office of the Auditor General
ASDB Mission: To work together with
parents, school districts, advocacy
organizations, and business and community
members to create nurturing environments in
which children with a vision or hearing loss
feel valued, develop their abilities, strive to
achieve academic excellence, and develop
skills to help them become productive and
responsible members of society.
Source: Fiscal Years 2010-2013 master list of state
government programs.
AdvancED.1 The Arizona School for the Deaf offers educational and
support services, including instruction in a direct communication
environment and counseling (see textbox), as well as training that
teaches students with cochlear implants to hear and understand speech
and other sounds. At the Arizona School for the Blind, services are
provided based on an expanded core curriculum that includes state
standard curriculum and special services such as orientation and mobility
training, braille, visual efficiency training, assistive technology, and
compensatory skills and tools. Both schools also offer other services
based on students’ needs, including activities of daily living; social skills;
occupational, physical, and speech therapy; and residential services.
• Phoenix Day School for the Deaf (283 students)—According to
ASDB officials, the Phoenix school educates students who are deaf or
hard-of-hearing and live within 60 miles of the metropolitan Phoenix area.
It provides educational and support services similar to the Arizona School
for the Deaf. The school supports students developing two languages—
1 AdvancED is an organization of public and private schools in the United States and other countries world-wide that
accredits schools based on adherence to quality standards in several areas, including curriculum, instructional design,
and assessment practices. The organization was formed in 2006 from the North Central Association Commission on
Accreditation and School Improvement, the Southern Association of Colleges and Schools Council on Accreditation
and School Improvement, and the National Study of School Evaluation.
page 2
State of Arizona
Direct Communication Environment—
Direct communication and access are a
critical part of education and language
development. Students who are deaf or
hard-of-hearing interact directly with
teachers, staff, and peers every day in
the classroom, cafeteria, after-school
program, and residential program. Direct
access to instruction and peer
interaction leads to enhanced
educational, social, and emotional
development; and allows a greater
degree of independence, self-confidence,
and self-advocacy.
Source: Arizona School for the Deaf Web site.
Table 1: Student Enrollment by Type of Disability
School Year 2011-2012
1 According to ASDB officials, “other” refers to a student with a sensory impairment who also has a medical
condition or a physical impairment.
2 According to ASDB officials, multiple disabilities are not identified in preschool children but are identified at a
later age.
Source: Auditor General staff analysis of ASDB’s April 2012 report, Agency enrollment: school year 2011-2012.
Program
Deaf or
Hard-of-
Hearing
Visually-
Impaired
Multiple
Disabilities
with Sensory
Impairment
Multiple
Disabilities
with Severe
Sensory
Impairment
Other with
Sensory
Impairment 1
Total
Students
ASDB Campuses
Arizona School for
the Blind
0 35 22 28 0 85
Arizona School for
the Deaf
79 0 16 15 0 110
Phoenix Day School
for the Deaf
211 0 40 32 0 283
Regional Cooperatives
Desert Valleys 160 51 80 92 1 384
Eastern Highlands 34 17 42 19 3 115
North Central 99 28 69 58 9 263
Southeast 130 36 88 39 15 308
Southwest 57 10 29 23 1 120
Preschool2 154 107 0 0 38 299
Total 924 284 386 306 67 1,967
American Sign Language (ASL) and English—and its curriculum parallels the
curriculum provided by public schools with modifications to meet students’
communication needs. According to ASDB officials, the school also offers
intensive instruction in functional and daily living skills for students who need it.
The school is accredited by AdvancED.
• Regional cooperatives (1,190 students)—ASDB provides educational and
support services in students’ local schools through five regional cooperatives
located in various parts of the State (see Figure 1, page 4). The Legislature first
authorized ASDB to establish regional cooperatives in 1988 to provide various
services that would enable districts to serve sensory-impaired students in a cost-effective
way and enable these students to reach their individual potentials by
providing access to the general education curriculum in district schools.
According to ASDB officials, the regional cooperatives provide access to a pool
of specially trained personnel and equipment, such as sign language interpreters
and braille-writer machines.
In addition to enrolling students at its campuses or in regional cooperatives, ASDB
provides services through the following programs:
• Birth to 3 program (273 children)—In cooperation with the Arizona Early
Intervention Program (AzEIP, see textbox on page 18), ASDB provides federally
mandated services for families of/and children ages birth to 3 who have hearing
or vision loss or who are deaf-blind. The program provides a comprehensive and
coordinated interagency system of early intervention services in the child’s home
and is designed to work in cooperation with other agencies and programs to
support the child and family’s needs. In addition to assessments that determine
if an infant or toddler is eligible for the program and to plan appropriate services,
the AzEIP program offers service coordination, assistive technology devices,
family training, physical and occupational therapy, and speech-language
pathology services.
• Preschool program (299 students)—ASDB
provides preschool education to eligible children,
ages 3 to 5, at its campuses in Tucson and
Phoenix and in classrooms in public schools
throughout Tucson and Phoenix. The services
offered to the children include preschool education,
educational assessment, vision and audiological
assessments, orientation and mobility services,
and speech therapy.
ASDB’s campuses and other programs serve students
with vision or hearing loss, including students with
multiple disabilities if at least one of the disabilities is a
visual or hearing impairment (see textbox). In the 2011-
2012 school year, most students ASDB served state-page
3
Office of the Auditor General
Multiple disabilities—Learning and developmental
problems that require special education and related
services and that result from two or more of (1)
hearing impairment, (2) orthopedic impairment, (3)
moderate intellectual disability, and (4) visual
impairment, or any of those conditions concurrently
with mild intellectual disability, emotional disability, or
specific learning disability.
Multiple disabilities with severe sensory
impairment—Multiple disabilities that include (1)
severe visual or hearing impairment with another
severe disability or (2) severe visual and severe
hearing impairments.
Source: A.R.S. §15-761
page 4
State of Arizona
Source: Auditor General staff analysis of data received from ASDB’s regional cooperatives as of April 2012.
Figure 1: Regional Cooperatives, School Districts, and Students Served
As of April 2012
Mohave
Coconino
Yavapai
La Paz
Yuma
Pinal
Graham
􀀪􀁕􀁈􀁈􀁑􀁏􀁈􀁈
Pima
Cochise
Santa
Cruz
Maricopa
Gila
Navajo Apache
North Central Regional Cooperative
􀁴􇐀􀀁􀄀 􀀔􁐀􀀕􁔀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀓􁌀􀀗􁜀􀀔􁐀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑅
Eastern Highlands
Regional Cooperative
􀁴􇐀􀀁􀄀 􀀓􁌀􀀒􁈀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀒􁈀􀀒􁈀􀀖􁘀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑓
Southeast Regional Cooperative
􀁴􇐀􀀁􀄀 􀀕􁔀􀀓􁌀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀔􁐀􀀑􁄀􀀙􁤀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑄
Desert Valleys Regional Cooperative
􀁴􇐀􀀁􀄀 􀀕􁔀􀀒􁈀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀔􁐀􀀙􁤀􀀕􁔀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅑓
Southwest Regional Cooperative
􀁴􇐀􀀁􀄀 􀀚􁨀􀀁􀄀􀀥􂔀􀁊􄨀􀁔􅐀􀁕􅔀􀁓􅌀􀁊􄨀􀁄􄐀􀁕􅔀􀁔􅐀􀀁􀄀􀁂􄈀􀁏􄼀􀁅􄔀􀀁􀄀􀁐􅀀􀁕􅔀􀁉􄤀􀁆􄘀􀁓􅌀􀀁􀄀􀁆􄘀􀁏􄼀􀁕􅔀􀁊􄨀􀁕􅔀􀁊􄨀􀁆􄘀􀁔􅐀
􀁴􇐀􀀁􀄀 􀀒􁈀􀀓􁌀􀀑􁄀􀀁􀄀􀀴􃐀􀁕􅔀􀁖􅘀􀁅􄔀􀁆􄘀􀁏􄼀􀁕􅔀􀁔􅐀
page 5
Office of the Auditor General
wide had a hearing loss, with smaller numbers of students with a vision loss or multiple
disabilities (see Table 1, page 2).
Board and staff
ASDB’s Board of Directors (Board) is responsible for the governance of ASDB,
including setting policy and appointing, evaluating, and determining whether or not to
offer a new contract to ASDB’s Superintendent. It has ten members, including the
Governor and the State’s Superintendent of Public Instruction who serve as ex officio
members. The Governor appoints the remaining members, who serve 3-year terms.
The appointed members include:
• One member from the Commission for the Deaf and the Hard-of-hearing;
• One member from the Governor’s Council on Blindness and Visual Impairment;
• One school district employee who works with his or her district’s program for
sensory impaired pupils; and
• Five additional members. A.R.S. §15-1321 requires the Governor to give
preference to people with experience and knowledge of sensory-impaired
education for three of these members.
ASDB has staff at its three school campuses and at its five regional cooperatives that
are located in various parts of the State. As of May 2012, ASDB reported that it had
803 full-time equivalent (FTE) positions, with 256 vacancies. The vacancies included
78 teachers; 38 instructional assistants; 47 educational interpreters, audiologists, and
transcribers; 9 drivers; and 84 various other positions.
ASDB’s staffing includes the following:
• Administration—The administrative staff include a superintendent who serves as
the executive officer for ASDB, an assistant superintendent, and principals for
each school. In addition, ASDB has directors over operations, regional
cooperatives, information technology, and human resources; a staff development
specialist; and an accountability specialist.
• Teaching and educational support—As of May 2012, ASDB employed 227.75
teachers and 20 supervisory teachers. Educational support includes 11.25
audiologists, 4.25 braillists, 1 ASL specialist, 3.25 speech/language pathologists,
and 65.75 educational interpreters. The educational interpreters work at the
regional cooperatives. ASDB’s teachers and other educational staff generally
have special training and certification in communicating with and teaching
students with sensory impairments.
page 6
State of Arizona
• Other—ASDB’s on-campus staff in Tucson also include night supervisors,
residential hall team leaders, and live-in staff for the student dormitories. These
staff also include teaching parents, who are educators responsible for working
with students on goals in areas such as personal care, recreation and leisure,
and domestic life. In addition, ASDB’s operations staff include custodial,
maintenance, security, food service, and equipment repair staff as well as full-time
and part-time drivers.
Budget and finances
As shown in Table 2 (see page 7), ASDB received approximately $55.5 million, $56.5
million, $54.7 million, and $53.8 million in annual net revenues in fiscal years 2009
through 2012, respectively. These revenues included:
• Special education voucher monies from the Arizona Department of
Education (ADE) to reimburse ASDB for educational costs based on its
enrollment—These monies are provided for students at ASDB’s three campus
schools and some students enrolled in ASDB’s regional cooperative program.
In the 2011-2012 school year, the voucher amount was $19,122.39 for each
visually-impaired student and $19,008.02 for each hearing-impaired student.
For each student who receives services through the regional cooperative
program, ASDB and the student’s district decide whether ASDB or the district
will collect the voucher monies.
• Payments from school districts for services provided by the regional
cooperative program—These include membership fees to participate in the
regional cooperative program and fee-for-service payments for students whose
voucher monies are retained by the district. Fee-for-service payments vary
depending on the level of service provided by ASDB. In the 2011-2012 school
year, the payments ranged from $2,800 annually for a student receiving 1 hour
per month of services to $21,500 annually for a student receiving 10 to 15 hours
per week of services (See Finding 2, pages 27 through 39, for additional
information on the fees charged for services provided through ASDB’s regional
cooperative program).
• State General Fund appropriations made directly to ASDB—State General
Fund appropriations help bridge the gap between the cost of educating ASDB
students and the amounts provided by special education vouchers and fees
paid by school districts. In fiscal year 2012, ASDB received a $20.8 million State
General Fund appropriation.
As shown in Table 2, ASDB’s total expenditures ranged between nearly $55.2 million
in fiscal year 2009 to approximately $54.5 million in fiscal year 2012. Most of ASDB’s
expenditures are for personal services and related benefits. These monies pay for
teachers and other staff at the three on-campus schools, teachers in the regional
page 7
Office of the Auditor General
1 Amount is primarily composed of educational reimbursements from the Arizona Department of Education based on enrollment and is determined by
statutory formula. The amount also includes federal grant revenues that are either received directly or passed through from the Arizona Departments of
Economic Security or Education.
2 Amount consists of revenues received from Arizona school districts for services rendered by ASDB’s regional cooperatives on a fee-for-service basis.
3 Amount primarily consists of interest and rental income.
4 Amount consists of transfers to the State General Fund in accordance with Laws 2008, Ch. 285, §46; Laws 2010, Ch. 1, §148 and 7th S.S., Ch. 3, §8; and
Laws 2011, Ch. 24, §§108, 129, and 138 to provide support for state agencies.
5 Amount primarily consists of transfers to the Arizona Department of Economic Security for required matching to obtain federal monies. According to
ASDB, the fiscal year 2009 required match was not made until fiscal year 2010; therefore, the transfer is reported in fiscal year 2010. Similarly, the fiscal
year 2012 required match was not made until August 2012; therefore, it will be reported in fiscal year 2013.
6 According to ASDB, end-of-year fund balances consist of revenues from several dedicated funding sources such as federal grants, Proposition 301
(2000) sales taxes, and educational reimbursements from the Arizona Department of Education. The balances are generally needed for cash flow at the
beginning of the next fiscal year or are restricted for specific purposes. For example, in order to pay the payroll costs for current 12-month employees
and purchase equipment, supplies, and materials needed for the start of the school year, the balances are needed in July and August since educational
reimbursements from the Arizona Department of Education, fees for services, or membership fees are not received until late September.
Source: Auditor General staff analysis of the Arizona Financial Information System (AFIS) Accounting Event Transaction File for fiscal years 2009 through 2012
and the AFIS Management Information System Status of General Ledger-Trial Balance screen for fiscal years 2010 through 2012.
Table 2: Schedule of Revenues, Expenditures, and Changes in Fund Balance
Fiscal Years 2009 through 2012
(Unaudited)
2009 2010 2011 2012
Revenues:
State General Fund appropriations $ 21,351,663 $ 21,580,479 $ 21,511,083 $ 20,802,910
Intergovernmental1 31,373,770 31,646,493 29,759,177 29,544,022
Educational and support service fees2 2 ,216,073 2 ,949,195 2 ,913,044 2 ,885,938
Other3 515,669 336,512 484,947 574,821
Gross revenues 55,457,175 56,512,679 54,668,251 53,807,691
Remittances to the State General Fund (12,034) (1,292)
Net revenues 55,445,141 56,511,387 54,668,251 53,807,691
Expenditures and transfers:
Personal services and related benefits 44,215,881 43,421,888 40,744,344 42,882,990
Professional and outside services 3,563,179 3,215,689 3,943,356 3,550,435
Travel 310,034 300,216 289,665 283,635
Food 255,407 231,084 232,703 237,015
Aid to individuals 1,110
Other operating 5,798,761 5,783,749 6,582,648 4,833,542
Equipment 1,034,733 2,100,684 2,451,489 2,715,179
Total expenditures 55,179,105 55,053,310 54,244,205 54,502,796
Transfers to the State General Fund4 157,200 18,200 531,100 616,400
Transfers to other agencies5 1,063,064 461,882
Total expenditures and transfers 55,336,305 56,134,574 55,237,187 55,119,196
Net change in fund balance 108,836 376,813 (568,936) (1,311,505)
Fund balance, beginning of year 6,506,384 6,615,220 6,992,033 6,423,097
Fund balance, end of year6 $ 6,615,220 $ 6,992,033 $ 6,423,097 $ 5,111,592
cooperative program who travel to the surrounding school districts in their respective
regions throughout the State, and administrative staff. These expenditures also
include salaries and benefits for the staff who provide student transportation to and
from the day school programs, which totaled approximately $2.9 million in fiscal year
2011, according to the fiscal year 2011 Annual Report of the Arizona Superintendent
of Public Instruction and other financial information obtained from ASDB.
page 8
State of Arizona
ASDB can do more to promote
student success
FINDING 1
page 9
ASDB aims to prepare students for future
ASDB’s mission is to work with parents, school districts, and others to enable
children with a vision or hearing loss to develop their abilities, strive to achieve
academic excellence, and develop skills to help them become productive and
responsible members of society. This mission aligns with ASDB’s statutory
responsibility to provide educational services, including instruction in a direct
communication environment, so that deaf, hard-of-hearing, and visually-impaired
students may become self-sustaining and useful citizens.
ASDB’s surveys of recent graduates show that many of its on-campus
students either continue their education or begin working, either independently
or with supports, such as a job coach. In 2011, ASDB reported that the Arizona
School for the Blind had 13 graduates, the Arizona School for the Deaf had 14
graduates, and the Phoenix Day School for the Deaf had 15 graduates.
Surveys conducted approximately 1 year after the students graduated
indicated that the students became involved in a variety of activities. For
example:
• Out of 13 survey respondents who graduated from the Arizona School for
the Blind in 2011, 9 reported that they were participating in work enclave
programs through the Department of Economic Security. Work enclaves
are competitive work site jobs where workers with disabilities are
supervised by program staff and receive a special wage commensurate
with their abilities.
• All 6 2011 graduates of the Phoenix Day School for the Deaf who
responded to the survey and 10 of the 14 respondents from the Arizona
School for the Deaf reported that they were in college or community
college, working, or volunteering. For example, one graduate worked part-time
as a physical therapist assistant after graduation and then resigned
to attend Gallaudet University where he is studying physical therapy.
Another graduate volunteers at the public library for 6 hours per week, a
third works in a supported-employment program sponsored by the
Department of Economic Security, and three graduates were attending a
community college for the deaf in Texas.
The Arizona State Schools
for the Deaf and the Blind
(ASDB) can make
improvements in its use of
best practices to help
ensure that its students
make good educational
progress and are prepared
for their future. Although
ASDB uses standardized
tests to assess individual
student progress, these
tests are somewhat limited
in their ability to assess
ASDB’s students’ progress
and provide relatively
limited information for
comparing ASDB to other
schools that educate
similar students. Thus,
attention to best practices
recommended by experts
and officials at other
schools is particularly
important. ASDB follows
many of these best
practices, including using
technology and modifying
instruction and services to
meet students’ particular
needs.
In four respects, however,
ASDB can strengthen its
efforts. These are:
• Improving its early inter-vention
program; • Seeking ways to increase
students’ access to
highly qualified teachers; • Compiling and using
information about its
graduates to improve its
programs; and • Studying differences in its
students’ test scores and
establishing expectations
regarding practices to
improve students’ test
scores.
Office of the Auditor General
ASDB uses several assessments to measure student
progress
To monitor students’ progress, ASDB relies on several different assessment
mechanisms. These include the same standardized test all Arizona students take, as
well as additional standardized tests, including the Measures of Academic Progress
(MAP), that provide more information on individual student progress. In addition, at
least once a year, ASDB staff will review each student’s progress toward the individual
goals established in his or her Individualized Education Program (IEP) (see textbox,
page 11). Each student’s IEP determines what assessments will be used to measure
the student’s progress, and results are reviewed when the IEP is updated.
ASDB frequently uses the following tests:1
• Arizona’s Instrument to Measure Standards (AIMS)—This is the standardized
assessment taken by all Arizona students in all school districts. The federal No
Child Left Behind Act requires that each state adopt standardized assessments
that align with state standards to demonstrate adequate yearly progress toward
the goal of narrowing achievement gaps. The State of Arizona uses AIMS (see
textbox, page 11) as its standards-based assessment.2 Arizona does not
require special education students to pass the test to meet the requirements for
a high school diploma unless their IEP requires it.
• Measures of Academic Progress (MAP)—This test, created by the Northwest
Evaluation Association (NWEA), assesses the same content as the AIMS,
according to an NWEA official. However, it is an interactive form, meaning that
it does not test a student on more advanced concepts if he/she did not answer
the initial basic concept question correctly. According to ASDB, this type of test
is particularly useful for students who are not performing at grade level because
it provides more information about students’ actual performance levels and their
progress over time than the AIMS does. ASDB administers the test to only some
on-campus students. ASDB officials reported that ASDB encourages all
students to take the MAP if they are able to do so. In spring 2011, approximately
59 percent of ASDB on-campus students took a MAP reading and/or math test.
1 In addition to AIMS and MAP, ASDB reported that it uses other assessments to measure student progress. For example,
it uses the Stanford Achievement Test (SAT-10) in second and ninth grades, as required by the Arizona Department of
Education. In addition, ASDB uses Teaching Strategies GOLD, another Arizona Department of Education required test
for special education children in preschool and kindergarten. For children aged birth to 3 years, ASDB reported that it
also uses the Developmental Assessment of Young Children test for deaf children and the Oregon Project for blind
children to assess the children’s cognitive skill level. ASDB also reported that it uses the 6-Traits Writing Rubric to
evaluate student writing samples, the Fairview assessment focusing on American Sign Language development, the
STAR Reading assessment, Work Sampling—an observational assessment containing grade-level samples of what
students should know and how they would demonstrate their knowledge—and classroom-type tests.
2 This report uses AIMS to refer to both AIMS and AIMS A, the alternate assessment used for some students. Both tests
report student results in the same way, indicating that the student exceeds, meets, approaches, or falls far below
standards.
page 10
State of Arizona
Arizona does not require
special education students
to pass the AIMS test to
obtain a high school
diploma unless their IEP
requires it.
Tests scores showed some academic progress, but
comparative information for assessing program success
is limited
ASDB students, on average, underperformed on standardized tests, although they
made some progress throughout their school years. For several reasons, however,
standardized tests such as AIMS and MAP are limited in their ability to assess the
progress of students with these types of impairments, and state-wide information that
would allow comparisons between ASDB and other Arizona schools educating similar
students is also limited.
Most ASDB students who took AIMS did not meet standards—Students
attending ASDB, either on one of its campuses or through the regional cooperatives,
generally scored lower on AIMS than did Arizona students as a whole. Some ASDB
students passed and even exceeded standards on the AIMS, but most did not. As
shown in Figure 2 (see page 12), in spring 2011, only 5 percent of ASDB students
exceeded standards, and only 25 percent met standards when they took the AIMS
math test in 3rd through 12th grades. By comparison, 23 percent of all students
state-wide who took AIMS exceeded standards, and 36 percent met standards for
math in spring 2011. Similarly, only 2 percent of ASDB students exceeded, and 34
page 11
Office of the Auditor General
Assessment terms
Individualized Education Program (IEP)—Every child with a disability must have an IEP that shows the child’s level
of achievement, measurable annual goals, how progress toward the goals will be measured, and what services will
be provided to the child. The goals may include passing the AIMS if appropriate for the child, but Arizona Revised
Statutes (A.R.S.) §15-763 states that a special education student does not need to pass the AIMS to graduate from
high school unless this is required by the student’s IEP. A team that includes the child’s parent or guardian develops
the IEP and updates it at least annually. The federal Individuals with Disabilities Education Act, Arizona statutes, and
Arizona Department of Education regulations specify the requirements the IEP must meet.
Arizona’s Instrument to Measure Standards (AIMS) and AIMS Alternate (AIMS A)—Tests students’ grade-level
mastery of state academic standards in writing, reading, math, and science. AIMS A is an alternate assessment
based on alternate achievement standards for students with significant cognitive disabilities. Both AIMS and AIMS A
test students in 3rd through 8th grades and in high school beginning in 10th grade (or in 9th grade if the student
repeats that grade) until they pass the test because it is a graduation requirement for most Arizona students. Special
education students are not required to pass the test to receive a high school diploma unless stipulated in their IEP.
Test scores are classified into four levels: exceeds, meets, approaches, and falls far below standards, with exceeds
and meets defined as passing scores.
Measures of Academic Progress (MAP)—Nationally normed test developed by the NWEA of language usage,
reading, math, and science that uses an equal interval scale to allow charting progress from year to year. The test
adapts to a student’s performance by offering questions based on whether the student answered previous questions
correctly. ASDB tests on-campus students in 2nd through 12th grades.
Source: Auditor General staff analysis of information about AIMS, AIMS A, and the IEP obtained from the Arizona Department of Education Web site,
information about MAP from the Northwest Evaluation Association (test publisher) Web site, and A.R.S. §15-763.
In spring 2011, 5 percent
of ASDB students
exceeded standards, and
25 percent met standards
on the AIMS math test.
percent met standards in reading, compared to 9 percent and 65 percent,
respectively, for all students state-wide who took the AIMS reading test.
Approximately two-thirds of ASDB students who took the AIMS math or reading
tests did not meet the standards. AIMS test results for 2008 through 2010 show
that, in those years, ASDB students also had much lower rates for meeting and
exceeding the standards than students state-wide (see Appendix A, page a-i).
page 12
State of Arizona
Source: Auditor General staff analysis of AIMS and AIMS A spring 2011 test scores for all ASDB students enrolled in
the 2011-2012 school year, including on-campus students and regional cooperative students for whom ASDB
receives voucher funding, and state-wide AIMS and AIMS A results for spring 2011 published October 2011
by the Arizona Department of Education in its 2011 Technical Report.
Figure 2: Spring 2011 AIMS Test Results for ASDB Students and State-wide Students
0
10
20
30
40
50
60
70
Falls Far Below Approaches Meets Exceeds
Percent of Students
Reading
ASDB
State-wide
0
10
20
30
40
50
60
Falls Far Below Approaches Meets Exceeds
Percent of Students
Math
ASDB
State-wide
MAP results show students made some progress but were still testing
well below grade level—ASDB students’ test scores for MAP were well below
national norms, which are based on a stratified sampling of students throughout the
United States. ASDB students showed less improvement from one year to the next
during the elementary school years as compared to national norms for all students.1
However, the test is not separately normed for deaf or blind students. Beginning in
5th and 6th grades, ASDB students improved their performance in reading and
math, respectively, compared to national norms. Even so, ASDB students started at
a much lower level than national norms, so while limited growth occurred after 5th
and 6th grades and continued in high school, it was not sufficient to bring students’
scores within reach of national norms (see discussion of early intervention programs,
pages 18 through 21, for reasons ASDB students started at a lower level).
Specifically:
• ASDB on-campus students’ average MAP scores in 2nd grade were in the first
to second percentile in reading and the third to fourth percentile in math. This
result indicates that nearly all students nationally who took the MAP received
higher scores than ASDB students who took the test.
• By the 11th grade, ASDB students who took the MAP scored on average the
same as 3rd-grade students would in reading and scored slightly below the
average 4th-grade student in math. This reflects a slight gain in performance,
with results at the fifth to sixth percentile in reading and the seventh to eighth
percentile in math. On average, 11th-grade students nationally who took the
MAP scored at approximately the 50th percentile and scored the same as a
typical-11th grade student would.
Standardized test scores are limited as indicators of program
success—For several reasons, great care must be taken in inferring conclusions
from these results. Key limitations include natural disadvantages ASDB students
may face in taking standardized tests. Additionally, there is little comparative
information about scores attained by similar students in other settings in Arizona or
in schools elsewhere in the United States. Specifically:
• Students who are deaf or hard-of-hearing and students who are blind or
visually-impaired may have difficulty taking standardized tests—Students
attending ASDB have hearing and/or visual impairments or multiple disabilities
(see textbox, page 3, for information on multiple disabilities). According to
experts, language deficits and testing barriers make it more difficult for these
students to perform at national or state norm levels on any standardized tests.
Despite accommodations such as braille versions of tests and having test
directions read aloud or signed, barriers that affect student performance still
exist. For example, deaf students do not learn English in infancy, but the tests
are administered in English so deaf students are taking the test in their second
1 Auditors analyzed ASDB students’ spring test results for the MAP test for 2006 through 2011 and compared them with
the spring 2011 national results published by NWEA.
page 13
Office of the Auditor General
According to experts,
language deficits and
testing barriers make it
more difficult for sensory-impaired
students to
perform at national or
state norm levels on any
standardized test.
language. Additionally, blind students are unable to see illustrations, such as
graphs, used in standardized math tests.
• ASDB students’ scores cannot be reliably compared with results for
other sensory-impaired students in Arizona or nation-wide—Within
Arizona, the available information regarding student test scores makes it
difficult to compare ASDB students’ performance with the performance of
similar students throughout the State. A key reason is the way in which school
districts must report special education students’ test scores. Specifically, to
comply with Family Educational Rights and Privacy Act regulations, when
school districts submit test scores to the Arizona Department of Education,
they report all students with disabilities under the broad category of special
education. They do not report students’ specific disabilities because such
categorization could enable students to be individually identified in published
reports. Therefore, sensory-impaired students’ test scores are reported in the
same category as students with learning disabilities, developmental delays,
and other disabilities. Further, although the Arizona Department of Education
has data regarding all Arizona students, including their specific disabilities that
could be matched with test scores, Arizona Department of Education officials
reported that this specific data may not be complete. As a result, the available
information does not provide an accurate way to compare the State’s entire
population of sensory-impaired students by disability.
Similar problems exist when attempting to compare ASDB students to
sensory-impaired students in other states. First, each state administers
different tests to measure students against their state’s standards. This makes
it difficult to compare students’ progress across states. Second, states differ
in the degree to which they require sensory-impaired students to take
standardized tests required of other students. Some deaf and blind schools
must participate in their states’ standardized testing. For example, students at
Perkins School for the Blind in Massachusetts are required to pass the state
test in order to obtain a high school diploma. Additionally, Alabama requires
all high school students to take the state test to graduate with a diploma, and
eligible students with disabilities who do not pass the test can obtain an
occupational diploma instead of the regular high school diploma. However,
similar to Arizona, at least two other states do not make passing the
standardized test a graduation requirement for all deaf and blind students.
Specifically, Florida School for the Deaf and the Blind students and Texas
students who are deaf or blind can receive waivers from testing requirements
for a high school diploma as long as the students can demonstrate in some
other way that they have met state standards. Additionally, at least two states’
deaf and blind schools have admission policies that restrict or deny admission
of severely impaired students. This would greatly impact the comparability of
those schools’ test results with ASDB’s test results as students with severe or
multiple impairments often struggle with passing standardized tests.
page 14
State of Arizona
When school districts
submit test scores to the
Arizona Department of
Education, they report all
students with disabilities
under the broad category
of special education.
page 15
Office of the Auditor General
Although there is a lack of comparison information regarding blind and multiply
disabled students’ test scores, some limited studies have been conducted for
deaf students. For example, a 2005 study found that the SAT-9 reading
comprehension score for 17- and 18-year-old deaf and hard-of-hearing
students was approximately equivalent to that of 4th-grade hearing students,
and a 2012 longitudinal study reported that deaf 17-year-olds’ SAT-9 math
scores approached the 6th-grade level.1,2 In addition, test results for a small
number of students at a small number of schools for the deaf nation-wide
suggest that ASDB deaf and hard-of-hearing students’ scores are similar to
those of their peers at other schools.3
ASDB uses commonly used practices but can work to
improve
Given the limitations of test results as a way to gauge ASDB’s success, auditors
looked for other ways to assess ASDB’s efforts. One commonly used assessment is
the degree to which an organization employs “best practices”—that is, those
approaches and techniques that experts, researchers, and practitioners have identified
as likely characteristics of a well-performing program. Although scientific research is
limited regarding what works in educating deaf and visually-impaired students, experts
have identified several commonly used practices. ASDB already follows a number of
these practices. However, it should focus additional effort in four key areas in order to
promote its students’ success: early intervention, increasing its students’ access to
highly qualified teachers, using surveys of its graduates to identify ways to improve its
programs, and developing ways to improve students’ scores on standardized tests.
Research is limited—Experts in the fields of deaf and blind education have
conducted extensive reviews of existing research and concluded that there is not a
large body of empirical research to draw upon to establish evidence-based
practices.4 This contrasts with research in educating children with more common
characteristics such as learning disabilities. However, experts at Gallaudet University,
a prominent university for deaf students in Washington D.C., and Perkins School for
the Blind in Massachusetts, as well as officials at deaf and blind schools in Texas
1 Gallaudet Research Institute. (n.d.). Literacy & deaf students. Retrieved, July 10, 2012, from http://www.gallaudet.edu/
gallaudet_research_institute/publications_and_presentations/literacy.html
2 Qi, S. & Mitchell, R.E. (2012). Large-scale academic achievement testing of deaf and hard-of-hearing students: past,
present, and future. Journal of Deaf Studies and Education, 17(1), 1-18.
3 The results from the other schools are preliminary. The test publisher cautions that because of the small number of test
scores included and the lack of stratification, the results should not be used for comparison as part of a decision-making
process. The data does represent a set of grade-level averages of test results of students identified as being deaf over
a number of years.
4 Luckner, J.L., & Handley, C.M. (2008). A summary of the reading comprehension research undertaken with students who
are deaf or hard-of-hearing. American Annals of the Deaf, 153(1), 6-36; and Douglas, G., McCall, S., McLinden, M., &
Pavey, S. (2009). International review of the literature of the evidence of best practice models and outcomes in the
education of blind and visually-impaired children. Trim, Co. Meath, Ireland: National Council For Special Education.
Test results for a small
number of schools for the
deaf nation-wide suggest
that ASDB deaf and hard-of-
hearing students’
scores are similar to those
of their peers at other
schools.
page 16
State of Arizona
and Florida, shared information with auditors regarding practices they have found
to be effective in educating deaf, hard-of-hearing, and visually-impaired students.
ASDB follows some commonly used practices—ASDB uses some
commonly used practices that are consistent with those identified by the experts
and practitioners auditors interviewed although there is a shortage of direct
evidence demonstrating practices are effective with deaf and blind students.
These include using technology to help students learn and adjusting instruction to
meet students’ needs. Specifically:
• Technology innovations help students learn—Experts and national deaf
and blind advocacy organizations indicated that innovations in technology are
vital to student advancement. These technological innovations help improve
deaf and blind students’ ability to access information. For example, an official
with the National Council of State Agencies for the Blind reported that portable
devices with refreshable braille displays enable blind students to keep up with
note taking and reading requirements in high school and beyond. Braille-reading
devices can allow students to access content as braille text or through
conversion to spoken words. Additionally, these portable devices allow blind
students’ access to Global Positioning Systems, which can enhance their
orientation and mobility skills and increase their independence. Another
assistive technology used by other states’ schools is distributed video in every
classroom. Distributed video uses smart whiteboards that bring the board
content to a screen on the student’s desk, and a swivel hinge allows visually-impaired
students to bring the screen as close as the student needs. Other
states’ schools also use technology to assist with their outreach programs by
providing webinars, online information, and training as well as publications
and other resources to professionals and families.
ASDB uses technology extensively and has developed a technology plan for
fiscal years 2011 through 2014, which identifies several technological
innovations to further make student learning a priority. ASDB already uses
technology such as computers and smart whiteboards in some classrooms,
computers in the library, video telephone booths, and refreshable braille
readers. The plan addresses several areas, including Reading/Language
Arts, Math, Highly Qualified Teachers, American Sign Language (ASL) and
Braille, Parent Involvement, and Technology Literacy. For each area, the plan
identifies a technology strategy and an action step with measurable goals. For
example, by the 2011-2012 school year, ASDB’s goal was to have all teachers
use digital video and other multimedia tools to promote language development,
and according to an ASDB official, this has been implemented. Another 2011-
2012 school year goal was that all students in the Arizona School for the Blind
would have accounts that would allow them to download library books in
braille. According to ASDB, this has also been implemented. Additionally,
ASDB plans to use interactive whiteboards for teaching math during the 2012-
2013 school year. ASDB also plans to build an accessible Web site for parents
ASDB uses technology
such as computers and
smart whiteboards in
some classrooms,
computers in the library,
video telephone, and
refreshable braille readers.
page 17
Office of the Auditor General
that will include trainings and tutorials as well as access to student events,
grades, and achievements for the 2012-2013 school year.
• ASDB modifies instruction and services to student needs—Other states’
deaf and blind school officials indicated that providing expanded curriculum
and individualized instruction, and grouping students based on ability level are
commonly used practices for educating deaf and/or blind students. At least two
other states’ deaf and blind schools have separate programs for students
based on their educational progress and needs. Specifically, the Florida School
for the Deaf and the Blind has three separate high school programs, including
one program that is specifically for students with additional conditions or needs.
Similarly, according to officials at the Texas School for the Blind and Visually-impaired,
their school has four separate academic programs with curriculum
designed to meet students’ needs. These programs include an academic
program designed for students functioning within 2 years of their grade level, an
academic program designed for students who are not yet reading at the first-grade
level, an academic program designed for students functioning more than
2 years below their chronological age, and a basic skills program for students
with multiple disabilities who learn best with consistent routines and meaningful
functional activities.
ASDB serves students with a wide range of needs, including students with
multiple disabilities and severe sensory impairments. Similar to public schools,
ASDB structures some of its classrooms by age and grade. However, ASDB
policy calls for placing students based on the student’s needs, and according
to ASDB staff, ASDB avoids assigning students with a wide range of academic
needs to the same classroom. Thus, an ASDB class may include students
grouped by academic ability level rather than age, and according to ASDB staff,
teachers must adapt instruction to meet each student’s individual needs. By
policy, ASDB classroom sizes are small, with student-teacher ratios ranging
from six to one for multiply disabled students with severe sensory impairments
to ten to one for deaf and hard-of-hearing students in elementary through
middle school grades. Typical classroom sizes range from five to nine students.1
ASDB also offers separate classes for students with additional disabilities or
higher need levels. According to ASDB staff, these classes cover the same
content as required by Arizona state standards, but the way in which the teacher
provides instruction may be different. For example, teachers may provide
reading materials at a lower level, e.g. fifth grade instead of tenth grade, for
those who have difficulty with reading comprehension or reading fluency.
According to ASDB staff, these classes usually also include a full-time teacher’s
aide.
1 Classroom sizes are based on 2011-2012 rosters for the Arizona School for the Blind and the Phoenix Day School for the
Deaf and 2012-2013 rosters for the Arizona School for the Deaf.
ASDB classroom sizes are
small, with student-teacher
ratios ranging
from six to one for multiply
disabled students with
severe sensory
impairments to ten to one
for deaf and hard-of-hearing
students.
Four areas require attention—Although ASDB follows some commonly used
practices, it can strengthen its practices in the following four ways:
• Early intervention and education critical to student success—The earlier
a child is identified as having a sensory impairment and receives services for
the impairment, the faster the child can begin learning the appropriate skills
to adjust to his/her environment. Research shows that the critical intervention
time for a baby who is deaf or hard-of-hearing is the first 3 years after birth,
and that the first 6 months after birth are crucial for the development of
communication and language skills.1 According to two other states’ deaf and
blind school officials, students who begin receiving specialized educational
services late may have missed the critical window when the brain is most able
to develop language, and these students may never catch up.
Experts indicated that early intervention services along with effective and
meaningful parent-child interactions help ensure successful outcomes in
areas such as vocabulary development, verbal reasoning skills, and social
interaction.2 The story of one ASDB student provided by ASDB staff illustrates
the positive outcome of early intervention and parent involvement:
◦ The student began receiving services almost immediately after birth. She
transitioned into preschool at Phoenix Day School for the Deaf and is now
in seventh grade, where she participates in sports, other activities,
and after-school events. In addition to early intervention,
ASDB staff reported that the mother’s involvement has
played a large role in the student’s success. While her
daughter was young, the Spanish-speaking mother began
learning sign language. Although the mother is not fluent in
ASL, she can communicate with her daughter and is very
involved in her daughter’s education by helping with
homework and communicating with her daughter’s teachers.
The student is progressing academically and scored above
the average ASDB student on MAP reading and math tests
in second through sixth grades.
ASDB provides early intervention services to sensory-impaired
students through the AzEIP program (see textbox).
The AzEIP program is responsible for providing early
intervention services to referred children and their families to
support children’s development. ASDB is one of the five
1 The National Agenda (2005). Moving forward on achieving educational equality for deaf and hard-of-hearing students.
Retrieved July 10, 2012, from http://www.ceasd.org/agenda/downloads/natl-agenda-2005-04.pdf
2 American Speech-Language Hearing Association. (2008). Service provision to students who are deaf and hard-of-hearing:
Birth to 36 months [Technical report]. Rockville, MD: Author; and Douglas, McCall, McLinden, & Pavey, 2009.
page 18
State of Arizona
Arizona Early Intervention Program (AzEIP)
The AzEIP is Arizona’s state-wide, interagency
system of supports and services for infants and
toddlers with developmental delays or disabilities
and their families. AzEIP services include
assistive technology devices and services, family
training, physical and occupational therapy,
vision and audiological assessments, orientation
and mobility services, and speech language
pathology services. The federal Individuals with
Disabilities Education Act, Part C, establishes
AzEIP to help provide eligible children and their
families access to services to enhance the child’s
development.
Source: Arizona Department of Economic Security AzEIP Web
site.
Experts indicated that early
intervention services along
with effective parent-child
interactions help ensure
successful outcomes in
vocabulary development,
verbal reasoning skills, and
social interaction.
agencies participating in the AzEIP program.1 ASDB’s AzEIP program
responsibilities for sensory-impaired children include evaluating and assessing
the child’s needs within 45 days of a referral; ensuring that the child has an
appropriate Individualized Family Service Plan (IFSP); providing or arranging for
the services on the IFSP in the appropriate intensity, frequency, and duration;
and participating in the transition and review of the child before the child enters
school. In addition, ASDB is responsible for various other tasks such as
coordinating with other AzEIP agencies, providing information for a state-wide
resource directory, and collecting and reporting data to the Department of
Economic Security.
Although ASDB complies with the 45-day requirement to assess children’s
sensory impairment needs and develop a service plan, it can improve in
regards to its other responsibilities within the AzEIP program. Specifically, as
part of the referral process, after a child has been identified as having a hearing
or visual impairment, ASDB is responsible for assessing the child’s sensory
impairment service needs and developing a service plan that will address these
needs within 45 days of a referral. According to an AzEIP official, ASDB meets
this 45-day time frame requirement. Adhering to this time frame for assessing
and then developing a plan to address service needs is important because
experts indicate that almost half of newborns who are referred from a hearing
screening do not have appropriate followup to determine the presence of a
hearing loss and to initiate appropriate early intervention services.2
However, ASDB should continue its efforts to improve in several other aspects
of its early intervention program. As of June 2012, ASDB had identified the
following areas for improvement:
◦ Coordination with other agencies—According to ASDB staff, it is working
with other state agencies that are part of the AzEIP program to collectively
establish contract services, such as therapists, that will allow referred
children and families to begin receiving services more efficiently. According
to ASDB staff, ASDB also plans to work with the Arizona Department of
Education and the Department of Economic Security to establish uniform
guidelines for the use of services provided to children when they transition
out of the AzEIP program and into schools.
◦ Staff training and certification—According to an ASDB official, ASDB plans
to provide training to its early intervention program staff to ensure that all staff
are using a consistent curriculum for early intervention services when they
work with children and families. In addition, ASDB reported it is taking steps
to ensure that its staff have a Standards of Practice certification as required
1 The five AzEIP participating agencies identified in A.R.S. §8-652 are the Department of Economic Security, ASDB, the
Arizona Department of Health Services, the Arizona Health Care Cost Containment System, and the Arizona Department
of Education. The Department of Economic Security oversees the program.
2 American Speech-Language Hearing Association, 2008
page 19
Office of the Auditor General
As part of the AZEIP
program, ASDB is
responsible for assessing
the child’s sensory
impairment service needs
and developing a service
plan within 45 days of a
referral.
by the AzEIP program, through which staff demonstrate the knowledge
and skills required to provide early intervention services.
◦ Organizational structure and staffing—According to ASDB staff, in June
2011, ASDB appointed a Tucson official to oversee its early intervention
program to help ensure the consistent operation of this program state-wide.
Prior to this change, ASDB’s regional cooperatives were responsible
for coordinating and managing early intervention services to children and
their families, which led to some inconsistencies within ASDB’s early
intervention program. In addition, ASDB is planning to revise staff job
descriptions to more accurately reflect the services it provides to children
and their families within the early intervention program and ensure staff
clearly understand their responsibilities.
◦ Outreach to families—ASDB has developed a new Web site that will
provide more detailed information to the public about resources available
through the AzEIP program as well as descriptions of all the programs
provided by ASDB, including early intervention, preschool, and school-age
programs. In addition, ASDB reported that it plans to use other outreach
mechanisms, including social networking sites such as Facebook,
YouTube, and Twitter, to reach more families that might benefit from its
services.
◦ Delays in starting services—ASDB plans to work with the Arizona
Department of Health Services’ Early Hearing Detection and Intervention
program to develop a new system that will allow ASDB staff access to
infant screening records so they can help ensure any child who fails a
screening receives appropriate assessments and other services in a timely
manner. In addition, ASDB is providing training to its staff to ensure any
delays in services are accurately reported to the Department of Economic
Security. The Department of Economic Security uses this information for
federal reporting requirements, to assess the reasons for the delay in
services, and to take appropriate action, if necessary.
◦ Compliance with state-wide AzEIP program requirements—The
Department of Economic Security’s review of ASDB’s early intervention
program for the period July 2010 through June 2011 found that ASDB did
not provide the required monthly service data to the Department of
Economic Security in a timely manner and included inaccurate information
in its database, which generates the monthly service data. The Department
of Economic Security uses the monthly service data to satisfy federal
government reporting requirements for the AzEIP program. The Department
of Economic Security also reported that ASDB’s IFSPs do not always
contain measurable goals, which are required by federal regulations.
Additionally, the review found that ASDB did not obtain sufficient parent
survey responses from one region of the State. This survey is used to help
page 20
State of Arizona
The Department of
Economic Security’s review
of ASDB’s early intervention
program for the period July
2010 through June 2011
found that ASDB did not
provide accurate service
data in a timely manner.
ensure that parents understand their rights regarding early intervention
services and that early intervention services have helped their children learn
and develop.
ASDB has developed performance improvement plans to address areas of
noncompliance with AzEIP requirements. Additionally, ASDB Information
Technology department has developed a plan to address issues with the
current database, and the official responsible for ASDB’s early intervention
program provided training to staff in December 2011 to help address data entry
practices.
• Highly qualified teaching staff important in
subject matter as well as in teaching techniques—
The federal Individuals with Disabilities Education
Act requires schools to hire highly qualified teachers
to teach students categorized as having disabilities
(see textbox). In addition, the No Child Left Behind
Act requires 100 percent of a school’s teachers of
core academic subjects, such as English,
mathematics, and reading or language arts, to be
highly qualified in the subjects they teach. Therefore,
all ASDB teachers must be highly qualified in
special education, and those who teach core
academic subjects must also be highly qualified in
the subjects they teach. Experts agree that students
make better progress when their teachers are
highly qualified in the subjects they teach, and
students with disabilities make better progress
when their teachers have specialized skills in
educating these students.
Most, although not all, ASDB teachers are highly
qualified in the subjects they teach, according to
ASDB. An Arizona Department of Education report
shows that approximately 10 percent of ASDB’s
teachers were not highly qualified in hearing-impaired
or visually-impaired special education
and/or in one or more of the subjects they taught
during at least part of the 2011-2012 school year.1
ASDB officials reported that the teachers who do
not meet the requirements are working toward
1 ASDB reports its teachers’ status to the Arizona Department of Education on October 1 each year, and according to ASDB,
updates the database occasionally throughout the year. As of May 7, 2012, the database showed that ASDB had 20
teachers out of the 213 listed who were not highly qualified in hearing-impaired or visually-impaired special education and/
or one or more of the subjects they were teaching. Because ASDB does not review and completely update the database
until closer to October 1, the number of teachers who were not highly qualified as of May 7, 2012, is likely higher or lower
than 20.
page 21
Office of the Auditor General
Highly Qualified Teachers—To be deemed highly
qualified, teachers must have a bachelor’s degree
and full state certification or licensure, and
demonstrate competency in each subject taught.
Demonstration of Competency—Teachers can
demonstrate subject competency with a major in the
subject, credits equivalent to a major in the subject,
passage of a state-developed test; a combination of
teaching experience, professional development, and
knowledge in the subject garnered over time in the
profession; an advanced certification from the state;
or a graduate degree.
No Child Left Behind Act Requirements—The No
Child Left Behind Act requires that teachers teaching
in core academic subjects in public elementary and
secondary school are highly qualified.
Individuals with Disabilities Education Act
Requirements—The Individuals with Disabilities
Education Act requires each person employed as a
public school special education teacher to be highly
qualified as a special education teacher.
Core academic subjects—English, reading or
language arts, mathematics, science, foreign
languages, civics and government, economics, arts,
history, and geography.
Source: U.S. Department of Education’s Individuals with Disabilities
Education Act Web site.
certification through professional development plans. According to ASDB,
many of these teachers are responsible for teaching multiple subjects, but
may be highly qualified in only one core subject.
According to ASDB staff, acquiring and retaining highly qualified staff is
difficult for many reasons, including a lack of competitive pay and the
challenges associated with obtaining the required certifications. Officials at
other deaf and blind schools and ASDB officials identified three possible ways
that deaf and blind schools can improve their ability to ensure that its students
are taught by highly qualified staff. The first way, used by a private school for
the blind in Massachusetts—offering tuition reimbursement and free room
and board to teachers while they work to become highly qualified—may not
be available to ASDB. The second way, increasing the pool of qualified
teachers in the State, which was suggested by a practice in Missouri, is
already under way in Arizona. Specifically, ASDB is working with the University
of Arizona and reported that it is also working with the Arizona Department of
Education to increase the number of hearing-impaired and visually-impaired
special education teachers in the State. ASDB is working with a University of
Arizona masters-level program that is intended to address the shortage of
highly qualified teachers needed to serve students who are deaf or hard-of-hearing
in Arizona, the Southwest, and the nation. The federally funded
program offers online, full- or part-time courses, and its objective is to
graduate 30 teachers who will be eligible for certification in the State of
Arizona.
A third approach used in Florida may offer additional potential for ASDB to
better ensure that its students take classes from highly qualified teachers.
Specifically, the Florida School for the Deaf and the Blind offers its students
the opportunity to take off-campus classes online. Experts have noted that
Web-based courses can make courses available to students without having
to employ highly qualified full-time teachers in each subject in each school,
and that states are choosing to implement online programs for special
education students in order to provide highly qualified teachers in subjects
where highly qualified teachers may be lacking.1 According to ASDB officials,
they are considering using online education classes to offer ASDB students
an opportunity to learn from highly qualified subject matter experts, with local
assistance from teachers who are highly qualified to teach sensory impaired
students. In fact, ASDB tentatively plans to enroll two Arizona School for the
Deaf students in math classes at an Arizona online charter school in the 2012-
2013 school year. ASDB should continue to seek opportunities, such as
alternative delivery classes, to increase its students’ access to highly qualified
teachers.
1 Thomas, W.R. (2002). Funding web-based courses for K-12 students to meet state educational goals. Atlanta, GA:
Southern Regional Education Board, and Muller, E. (2009). Serving students with disabilities in a state-level virtual K-12
public school programs. Alexandria, VA: National Association of State Directors of Special Education, Inc.
page 22
State of Arizona
ASDB is working with a
University of Arizona
masters-level program
intended to address the
shortage of highly
qualified teachers needed
to serve students who are
deaf or hard-of-hearing.
• Post-graduation tracking can help determine student progress and identify
areas that need improvement—Although ASDB has information about
students’ status 1 year after graduation, according to ASDB staff, it does not
compile or analyze the information and use it to improve its programs. Officials
at one state’s deaf and blind schools and a private school stated that tracking
students after graduation is necessary to identify areas in the curriculum that
could use improvement. For example, a state school for the deaf collected
information from its high school graduates to help determine why so many
students were dropping out of post-secondary education programs. The
information gathered indicated students did not feel prepared for dormitory life.
This enabled the school to restructure its high school program so seniors now
live in a dormitory setting that allows students to focus on living skills that are
required to succeed in college.
Similarly, ASDB could use the information collected from recent graduates to
improve its programs. Some comments received from seven students and
families who responded to auditors’ survey of 2011 ASDB graduates suggest
ways ASDB can consider modifying its programs. Specifically:
◦ Providing additional homework help;
◦ Offering group living to facilitate life skills development;
◦ Increasing opportunities to gain work and volunteer experiences; and
◦ Introducing vocational programs earlier.
ASDB should use the results of its surveys of students after graduation to
measure student progress and to identify and implement enhancements to its
students’ educational programs.
• Studying differences in test scores can help narrow achievement gaps—
The No Child left Behind Act requires that all public schools in every state work
towards narrowing achievement gaps in the state as measured by each state’s
standardized test, which in Arizona is AIMS. Studying differences in AIMS
passing rates across ASDB locations may hold some immediate assessment
benefits for ASDB. AIMS test results varied between ASDB’s on-campus
students and students receiving services from ASDB’s regional cooperatives
and among the regional cooperatives. At ASDB’s three campus schools, 74 to
94 percent of students’ spring math and reading scores fell below standards.
According to ASDB officials, on-campus students have higher needs because
of their disabilities, which may contribute to lower test scores. For example,
some students have secondary physical disabilities that cause absences from
school or learning disabilities that cause additional delays in development.
However, failure rates also varied between the five regional cooperatives.
Students at four of the five regional cooperatives passed AIMS at a higher rate
page 23
Office of the Auditor General
AIMS test results varied
between ASDB’s
on-campus students and
students receiving
services from ASDB’s
regional cooperatives and
among the regional
cooperatives.
than the on-campus students. For example, only 49 percent of the Eastern
Highlands regional cooperative students failed the reading test, compared to
77 percent of students in the Southwest regional cooperative where results
were more similar to results for the on-campus students. Examining these
variances more closely may help ASDB officials determine if teaching
practices vary among locations and whether higher scores in some regions
reflect more effective practices that should be implemented across all
locations.
To increase student achievement at all the regional cooperatives and on-site
campuses, ASDB should determine the reasons for variations in test scores
and identify potential solutions to improve test results, and establish
expectations that each campus and regional cooperative will implement best
practices to improve test performance.
Recommendations:
1.1 To help ensure that children with sensory impairments receive needed services,
ASDB should improve its early intervention program by continuing to take the
following steps:
a. Coordinating with other state agencies that are part of the AzEIP program
to establish contract early intervention services throughout the State;
b. Working with the Arizona Department of Education and the Department of
Economic Security to establish guidelines for the use of services provided
to children when they transition out of the AzEIP program and into schools;
c. Providing staff training to ensure that all staff use a consistent curriculum
for early intervention services and that staff accurately reflect delays in
starting services in ASDB’s database;
d. Ensuring that its early intervention program staff have Standards of
Practice certifications as required by the AzEIP program;
e. Revising the early intervention staff job descriptions to ensure they
accurately reflect the services ASDB provides to children and their
families;
f. Providing more detailed information to the public about resources
available through the AzEIP program, as well as descriptions of all the
programs provided by ASDB, including early intervention, preschool, and
school-age programs through its newly developed Web site;
page 24
State of Arizona
page 25
Office of the Auditor General
g. Using other outreach mechanisms, including social networking sites such
as Facebook, YouTube, and Twitter, to reach more families who might
benefit from its services;
h. Working with the Arizona Department of Health Services’ Early Hearing
Detection and Intervention program to develop a new system that will allow
ASDB staff access to infant screening records so they can help ensure any
child who fails a screening receives appropriate assessments and other
services in a timely manner; and
i. Addressing areas identified in the Department of Economic Security’s
review of ASDB’s compliance with state-wide AzEIP requirements.
Specifically, ASDB should:
◦ Provide accurate and timely monthly service data to the Department of
Economic Security;
◦ Improve staff data entry practices and establish procedures that will
help ensure the accuracy of data in ASDB’s database and the monthly
service reports that are generated from the database;
◦ Ensure that Individualized Family Service Plans contain appropriate
and measurable goals as required by the AzEIP program; and
◦ Encourage families to complete and return early intervention surveys.
1.2 ASDB should continue to seek opportunities, such as alternative delivery classes,
to increase its students’ access to highly qualified teachers.
1.3 ASDB should establish a process for compiling, analyzing, and using information
obtained from surveys about its students after graduation to measure student
progress, and to identify and implement enhancements to its students’
educational programs.
1.4 To narrow the achievement gaps and increase the AIMS passing rate among its
students, ASDB should:
a. Determine the reasons for variations in test scores and identify potential
ways to improve test results at the campuses and the regional cooperatives;
and
b. Establish expectations that each campus and regional cooperative will
implement best practices to improve test performance.
page 26
State of Arizona
ASDB should examine regional cooperative
program service fees and strengthen
program operations
FINDING 2
page 27
ASDB provides services to students at local school
districts through its regional cooperative program
As authorized by the Legislature, ASDB established a regional cooperative
pilot program and started providing services in 1988, and continues to operate
five regional cooperatives throughout the State (see Figure 1, page 4). The
intent of this program was to enable local school districts to serve deaf, hard-of-
hearing, and visually-impaired students in a cost-effective way by providing
access to a pool of specially trained personnel and equipment provided by
ASDB (see textbox). Regional cooperative staff travel to the participating
school districts and provide services to students as they remain at the schools
in their districts.
Each regional cooperative has a director who supervises operations and
various staff, including teachers, interpreters, other specialists, and
administrative staff who work with the member districts’ sensory-impaired
students. Regional cooperative teachers consult with school staff, classroom
teachers, parents, and students; provide specialized direct instruction to
students in their areas of need; prepare curricular modifications and
demonstrate techniques for working with individual students; and assist in
student placement by serving as members of the team that develops each
The Arizona State Schools
for the Deaf and the Blind
(ASDB) should take several
steps to improve the
operation of its regional
cooperative program,
including more fully
recovering program costs
and strengthening the
oversight and management
of the program. ASDB’s
regional cooperative
program serves as a
resource for school districts
by providing staff and
equipment to sensory-impaired
students in
member districts. However,
some fees charged by the
five individual regional
cooperatives are
inconsistent, and even for
the fees that are
consistently applied across
all cooperatives, ASDB has
no method to determine
whether the fees cover the
cost of the services
provided. In addition to
developing a structured
approach to review and
establish appropriate fees,
ASDB needs to review the
regional cooperatives’
advisory councils’ role in
fee-setting. Additionally,
ASDB should develop a
consistent way for regional
cooperatives to keep track
of student needs and staff
availability, as well as
equipment provided for
students’ use.
Office of the Auditor General
Overview of the regional cooperative pilot program
• Provide educational programs and related services to all
sensory impaired students if the school participates in
cooperative program and cannot provide an appropriate
placement for the student within the district.
• Provide supplemental services such as audiological and
vision assessments, specialized curriculum materials and
equipment, and district staff development assistance.
• Costs to be paid by participating schools.
• Locations decided by ASDB in consultation with districts.
• Each cooperative advised by committee, including parents,
districts, and local private service organizations.
Source: Auditor General staff summary of Laws 1987, Ch. 363, §19.
student’s Individualized Education Program (IEP) (see textbox, page 11). Each
regional cooperative also has an advisory council that provides advice on the
administration of the cooperative.
About half of Arizona’s school districts participate in the regional cooperative
program. School districts and other public schools, such as charter schools and
Bureau of Indian Affairs (BIA) community schools, must sign agreements with ASDB
if they elect to receive educational services for their deaf, hard-of-hearing, and
visually-impaired students through the regional cooperatives. In the 2011-2012
school year, 114 school districts and 33 other entities participated in the regional
cooperatives. In the 2011-2012 school year, the regional cooperatives served 1,190
students in these districts. According to a representative from a participating school
district, it benefits the district to participate in the regional cooperative because of the
costs the district would incur to obtain the services for its students elsewhere. Many
of the 116 districts in the State that did not participate in the regional cooperatives fell
into two groups: (1) large districts such as the Mesa, Chandler, and Tucson districts,
which use their own staff to provide these services, and (2) very small districts that
do not have any sensory-impaired students.
The regional cooperatives receive monies from various funding sources to pay for
the services provided to the students in the program. Funding sources for services
provided to students by ASDB’s regional cooperatives include the following:
• State General Fund appropriations—ASDB receives an annual appropriation
from the State General Fund for the regional cooperative program. In fiscal year
2013, the appropriation for the program was $803,500. According to ASDB staff,
ASDB uses these appropriations to cover its administrative costs for the regional
cooperatives, such as office rent, utilities, and administrative staff salaries and
employee-related expenses.
• School district membership fees—Each participating school district pays a
per-district membership fee to belong to a regional cooperative. The membership
fees are used to provide services that are not tied to a particular child’s IEP and
include assistance with screening and identification of children, evaluation of
children, and training of school staff.
• Special education vouchers—ASDB receives voucher monies from the
Arizona Department of Education for many of the regional cooperative students
it serves. Generally, ASDB receives voucher monies for students whose primary
disability is a hearing or vision impairment, while districts receive voucher
monies for students with multiple disabilities (see textbox, page 3, for the
definition of multiple disabilities). ASDB and districts work together to decide
which entity will receive the voucher monies. The amount of the educational
voucher is determined by statute, and as of the 2011-2012 school year, the
education voucher was $19,122 for visually-impaired students and $19,008 for
deaf and hard-of-hearing students. If ASDB receives voucher monies for a
page 28
State of Arizona
In the 2011-2012 school
year, 114 school districts
and 33 other entities
participated in the regional
cooperatives.
student, ASDB pays an amount to the district to reimburse the district for services
the district provides to the student such as transportation and any educational
services not provided by the regional cooperative.
• Fees for services—When a district rather than ASDB receives the Arizona
Department of Education voucher payment, it pays ASDB a fee for the services
ASDB provides. These services include ongoing assessment, instruction,
provision of equipment, and vocation counseling. The costs for services under the
fee-for-service structure depend on the number of hours of service provided. As
shown in Table 3 (see page 30) the levels of service, types of service, and annual
fee-for-service charges are uniform among all the cooperatives. For example,
districts pay $5,245 per year for a student who receives 1.5 hours of services per
week, and $21,500 per year for a student who receives 10 to 15 hours of services
on a weekly basis.
• Additional fees—ASDB receives additional monies from districts for services that
exceed what is outlined in the membership fees or fee-for-service amount. For
example, one regional cooperative’s membership fee for districts with less than
200 students covers 26 audiological assessments. If the number of assessments
exceeds 26, the cooperative charges $20 for each additional audiological
assessment.
ASDB should examine fees for regional cooperative
program services
ASDB should systematically examine the various fees that regional cooperatives
charge, make them more consistent, and ensure that they cover the costs of the
services provided. Although fee-for-service amounts and services are consistent state-wide,
many other fees or payments, such as membership fees paid by participating
districts and reimbursements paid to districts for transportation and other services, are
not consistent across regions. These inconsistencies create inequities in which some
districts’ payments subsidize other districts’ expenses. Further, ASDB has not
determined if the fees paid by districts for services provided by regional cooperative
staff cover the costs of the services. To resolve these issues, ASDB needs to develop
and implement a structured approach for determining appropriate fees and payments.
Membership and supplemental fees charged to districts and payments
to districts are inconsistent—ASDB has not established policies or
procedures for determining appropriate membership and supplemental fees for
school districts that participate in regional cooperatives or for determining the
amounts that the regional cooperatives should pay to reimburse district schools for
services provided to students for whom ASDB receives voucher monies. Instead,
each regional cooperative has developed its own membership fee and list of
services included in the membership fee. In addition, some have established
page 29
Office of the Auditor General
Each regional cooperative
has developed its own
membership fee and list
of services included in the
membership fee.
page 30
State of Arizona
1 The rates for BIA community schools are set by a separate process.
2 According to a regional cooperative official, a teacher typically provides an itinerant level service a couple of
times a week and the student receives visually-impaired or hearing-impaired services that complement the
district teacher’s teaching curriculum.
3 According to a regional cooperative official, a teacher provides a resource level service on a daily basis. The
student might receive some services from the district teacher.
Source: Auditor General staff compiled information from ASDB’s regional cooperatives.
Table 3: Services Provided by Regional Cooperative Staff
School Year 2011-2012
Service Level Type of Service Hours of Service
Service
per Year1
Consult indirect
Limited direct service 1 hour a month and
no equipment
provided
$2,800
Consult direct
Ongoing assessment and limited service 1 hour a month and
no equipment
provided
2,800
Level I itinerant2
Ongoing assessment, specialized and direct
instruction, provision of equipment, vocational
counseling, and direct service to student in
amplification use and listening skill training.
1.5 hours a week 5,245
Level II itinerant2
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary,
speech development, math, science, and
social studies. Direct service to student in
amplification use, listening skill training, and
sign language instruction.
1.5-3 hours a week
7,335
Level III resource3
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary,
speech development, math, science, and
social studies. Direct services to student in
amplification use, listening skill training, and
sign language instruction.
3-5 hours a week 11,000
Level IV resource3
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary and
speech development, math, science, and
social studies. Direct services to student in
amplification use, listening skill training, sign
language instruction, sign language
interpreting and note taking, and classroom
tutor or instructional aide.
5-10 hours a week 16,260
Level V resource3
Ongoing assessment, provision of equipment,
and vocational counseling. Direct services to
student in language, reading, vocabulary and
speech development, math, science, and
social studies. Direct services to student in
amplification use, listening skill training, sign
language instruction, sign language
interpreting and note taking, and classroom
tutor or instructional aide.
10-15 hours a week
21,500
additional supplemental fees. Further, each regional cooperative has determined an
amount it reimburses to districts for services the districts provide to students for
whom ASDB receives Arizona Department of Education voucher monies even
though the voucher amount is the same regardless of which district or cooperative
the student comes from. The resulting amounts vary, and the regional cooperatives
explained that the differences have historically existed. Specifically:
• Membership fees differ among regions—The regional cooperatives use
different tiers for grouping districts and setting membership fees based on
student population within the district (see Table 4). For example, the Southwest
regional cooperative has three tiers—districts with less than 500 students, 501
to 2,000 students, and more than
2,000 students, with different fees for
each tier. However, the Eastern
Highlands regional cooperative has
five tiers ranging from under 200
students to 5,000 or more students,
again with different fees for each tier.
Additionally, as shown in Table 4, the
range of membership fees charged
by each regional cooperative for their
various tiers differs for each regional
cooperative. For example, the fees for
the tier comprising the regional
cooperative’s smallest districts
ranged from $240 to $500 in 2011-
2012.
• Services covered by membership fees differ among cooperatives, and
some cooperatives charge supplemental fees for services, while others do
not—The services covered by the membership fees also differ from region to
region. As a result, some regional cooperatives charge additional fees for
supplemental services that some regional cooperatives include in the set of
services covered by the membership fees. For example, although most regional
cooperatives include district staff training in the membership fees, one regional
cooperative charges a separate fee of $25 per person to train district staff in
conducting hearing screenings. Another regional cooperative has additional
charges for certain services if they are provided to fee-for-service students—$71
per hour for mobility and orientation training and $45 per hour for interpreter
services. The other three cooperatives have not established similar additional
charges and instead provide these types of services with no additional charges.
• Reimbursements to districts inconsistent and not based on actual services
provided by districts—As previously mentioned, ASDB receives voucher
monies for students whose primary disability is a hearing or vision impairment
and for whom ASDB assumes the primary educational responsibility within
page 31
Office of the Auditor General
Table 4: Regional Cooperative Membership Fee Structure
School Year 2011-2012
1 Bureau of Indian Affairs community schools.
Source: Auditor General staff analysis of data received from ASDB’s regional
cooperatives.
Membership fees and supplemental fees differ among regions—
Regional
Cooperative
Number of
Tiers Membership Fee
Southeast 4 $260 up to $820
Desert Valleys 5 $280 up to $1,000
North Central
BIA Schools1
4
5
$240 up to $720
$280 up to $1,000
Eastern Highlands 5 $280 up to $1,000
Southwest 3 $500 up to $1,250
these students’ home school districts. If ASDB receives voucher
monies for a student, ASDB reimburses the district for services
the district provides to the student such as transportation and
any educational services not provided by the regional
cooperative. However, the regional cooperatives have set
differing reimbursement amounts, even though the voucher
amount is the same regardless of which district or cooperative
the student comes from. As shown in Table 5, the per-student
amounts range from no reimbursement for students in the
southeast region who are receiving specified services from the
regional cooperative to $3,500 annually for all students in two
regions and for some students in a third region.
The cumulative result of these inconsistencies can be substantial.
Table 6 (see page 33) shows examples of the differences that
can result, both for voucher students—those students for whom
ASDB receives the Arizona Department of Education voucher—
and for those students for whom the district receives the
voucher. For a visually-impaired voucher student, regional
cooperative 1 receives a membership fee of $260 and reimburses
the district $2,000, while regional cooperative 2 receives a
membership fee of $500 and reimburses the district $3,500. As
a result, regional cooperative 1 has $17,382 to cover the
students’ costs, while regional cooperative 2 has $16,122 to
cover the students’ costs, which is a difference of $1,260. For
fee-for-service students, the difference is less—$240—because
it relates only to the membership fee. As a result, the regional
cooperatives can have a different amount of monies per student
to cover the same services.
ASDB unable to determine if fees are adequate to cover costs—
ASDB policy requires its regional cooperatives’ advisory councils to recommend
a fee structure that will cover all costs of services that are not covered by legislative
appropriations. However, ASDB has not evaluated whether the membership fees
and fee-for-service amounts cover the costs of the services provided to regional
cooperative students. Although ASDB does not have records of past fees, officials
at three regional cooperatives reported that fees had not been changed since at
least 2007, and a fourth regional cooperative official said fees had not been
changed since before 1997. The fifth regional cooperative official reported that
fees had not changed since before 1992. Additionally, in fiscal year 2011, the
ASDB Cooperative Services Fund’s fund balance decreased, suggesting the fee
amounts may be inadequate to cover costs. Two regional cooperatives prepare a
report that shows some of the revenues and expenses associated with a district’s
students if the district requests the report. However, because this report does not
include all revenues and expenses and is prepared by only two of the five regional
cooperatives, ASDB cannot rely on it to determine whether its fees are adequate.
page 32
State of Arizona
Table 5: Regional Cooperative
Reimbursements to Districts
School Year 2011-2012
1 Without educational interpreter, instructional assistant,
orientation and mobility, and rehabilitation therapy.
2 With educational interpreter, instructional assistance,
orientation and mobility, rehabilitation therapy, and
educational transcriber.
3 If the student receives services involving two or more staff.
4 If a full-time sign interpreter or instructional assistant is
assigned to the regular education classroom.
Source: Auditor General staff compiled information from
ASDB’s regional cooperatives.
Regional Cooperative Reimbursement Amounts
Per Voucher Student
Southeast $2,0001
or
$02
Desert Valleys $3,500
North Central $2,700
or
$1,5003
Eastern Highlands $3,500
Southwest $3,500
or
$1,5004
ASDB has not evaluated
whether the membership
fees and fee-for-service
amounts cover the costs
of the services provided to
regional cooperative
students.
page 33
Office of the Auditor General
Although regional cooperatives independently establish their fees, ASDB combines
the revenues to pay regional cooperatives’ costs throughout the State. For example,
at the end of fiscal year 2011, the North Central regional cooperative’s portion of the
ASDB Cooperative Services Fund’s fund balance was negative $129,118, while the
Desert Valleys regional cooperative’s portion was more than $2.5 million. ASDB
used monies from the Desert Valleys regional cooperative to purchase 29 cars for
all of the regional cooperatives and to pay for a conference attended by all regional
cooperative staff. In effect, Desert Valleys regional cooperative member school
districts were subsidizing other regional cooperatives’ expenses.
ASDB needs to adopt structured approach to establishing fees—To
address the problems regarding inconsistencies in some fees and to determine
whether its fees cover the cost of services provided, ASDB needs to adopt a
structured fee-setting approach. A structured approach would allow ASDB to
evaluate current fees and propose new fees that would (1) fully cover costs related
to the services provided by the regional cooperatives and (2) ensure that specific
fees are appropriate for the services.
Mississippi’s Joint Legislative Committee on Performance Evaluation and Expenditure
Review (PEER) developed an approach for evaluating and setting fees that may
assist ASDB.1 PEER’s approach consists of a decision model for establishing or
increasing government fees, called the Theory of Fee Setting in Government, as well
1 Joint Legislative Committee on Performance Evaluation and Expenditure Review. (2002). State agency fees: FY 2001
collections and potential new fee revenues. Jackson, MS: Author.
Source: Auditor General staff compiled information from ASDB’s regional cooperatives.
Table 6: Example of Differences in Regional Cooperative Service Costs
School Year 2011-2012
Voucher Students
Regional Cooperative 1
Regional Cooperative 2
Difference
Membership fee
$ 260
$ 500 $ 240
Voucher 19,122 19,122 0
Reimbursement to
district
(2,000)
(3,500) (1,500)
Total per student
$17,382
$16,122 $1,260
Fee-For-Service
Students
Regional Cooperative 1
Regional Cooperative 2 Difference
Membership fee
$ 260
$ 500 $240
Level II itinerant
5,245
5,245 0
Total per student
$ 5,505
$5,745
$ 240
Although regional
cooperatives independently
establish their fees, ASDB
combines the revenues to
pay regional cooperatives’
costs throughout the State.
page 34
State of Arizona
as guidance on implementing new fees.1 Figure 3 (see page 35) summarizes key
concepts from PEER’s approach.
ASDB’s approach should include the following:
• Assessing efficiency of operations—ASDB should assess the efficiency of its
operations to ensure costs are as low as possible and document the results of
its assessment. As ASDB assesses the efficiency of its operations, it should
seek to minimize costs where possible.
• Developing a cost-accounting method—ASDB should determine whether to
consider costs independently for each regional cooperative or in combination
on a state-wide basis, and then develop and finalize a method for tracking and
allocating relevant service and equipment costs.
• Developing fees based on relevant costs—To help ensure fees are
appropriate and equitable, ASDB should identify the actual costs for specific
services for which fees are charged. In addition, fees should take into account
factors that affect the cost of the specific service. For example, some regional
cooperatives may incur more costs for transportation because these regional
cooperatives must transport staff and/or equipment greater distances to reach
the districts they serve.
Once developed, ASDB should use this approach to assess its fees and establish
new fees. If the new fees are substantially higher than existing fees, ASDB should
consider phasing in the increases over time. In addition, ASDB should develop and
implement policies and procedures for using the method to establish new fees.
ASDB should also develop a systematic way to determine whether and how much
to pay school districts for services provided to students for whom ASDB receives
Arizona Department of Education voucher monies. ASDB is not statutorily required
to pay the districts, but it has historically chosen to reimburse the districts for
transportation and other services. If ASDB continues its practice of reimbursing
districts, it should develop a process to determine the appropriate amount of these
reimbursements.
Regional councils’ role in fee-setting needs review
As ASDB develops a structured approach to setting fees, it also needs to examine
the fee-setting role played by the regional cooperatives’ advisory councils. Each
regional cooperative has an advisory council comprising representatives from
1 According to PEER, the approach was based on a review of academic literature, economics theory, and policies and
procedures from various states and the United States and Canadian governments.
If ASDB continues its
practice of reimbursing
school districts, it should
develop a process to
determine the appropriate
amount of these
reimbursements.
page 35
Office of the Auditor General
Figure 3: Mississippi Joint Legislative PEER Committee’s
Structured Fee-Setting Process
Developed for State Government
Source: Auditor General staff analysis of fee-setting model.
Determine whether fees or taxes should fund the service
Who benefits from the service: individuals, the public, or both?
􀁸􇡆 Fees should finance services that benefit individuals.
􀁸􇡔 Taxes should finance services that benefit the public.
􀁸􇡗 When both individuals and the public benefit from a service, financing can come
from both fees and taxes.
Identify and analyze legal issues
􀁸􇡁 Are fees limited by statute? If so, is legislation required to change them?
􀁸􇡓 Should administrative rules be revised?
Identify the fees’ purpose
􀁸􇡓 Should fees cover the cost of providing the service?
􀁸􇡓 Should fees be set to influence behavior?
􀁸􇡓 Should fees be set to encourage compliance with program regulation and goals?
Assess factors influencing fee amount
􀁸􇡗 What effect will fees have on those who pay them?
􀁸􇡗 What effect will fees have on annual revenue?
􀁸􇡗 What do similar states charge for the service?
􀁸􇡗 Will the public accept the fees’ necessity?
􀁸􇡉 Is the Department subsidizing other government operations?
Determine appropriate methodology for setting fees
􀁸􇡄 Determine if there is a comprehensive cost accounting system.
􀁸􇡓 Seek to reduce costs as much as possible.
􀁸􇡍 Measure direct and indirect costs of the time staff spends in service activities.
􀁸􇡄 Determine economic impact on regulated entities.
Implement fees
􀁸􇡏 Obtain amended legislation and regulation as needed.
􀁸􇡐 Prepare those who pay fees for changes by providing advanced notice and
explaining the purpose and reasoning of new fees.
􀁸􇡔 Train staff to answer questions regarding the new fees.
Periodically assess revenue, costs, and program outcomes to
update fee amounts
page 36
State of Arizona
participating public schools and ASDB staff. These councils have taken on the
responsibility of approving membership fees and reimbursement amounts.
Although neither statute nor ASDB policy requires an advisory council vote to
increase a regional cooperative’s membership fee or propose other changes in
reimbursement amounts, at least four of the regional cooperatives rely on the council
members’ vote to do so. The regional cooperatives hold annual or more frequent
meetings with their respective advisory councils. During these meetings, regional
cooperative staff inform council members of the regional cooperative budget, the
number of participating member districts, and any other important information
affecting the operations of the regional cooperative.
For two reasons, setting fees appears to be an inappropriate role for the advisory
councils. First, it goes beyond the role for these councils established in ASDB policy.
Under ASDB policy, the councils’ duties include making recommendations about
membership fees, but not actually setting them. By allowing the councils to determine
fees instead of providing recommendations for ASDB management to consider,
regional cooperative staff appear to have misinterpreted the advisory council’s
responsibilities. Second, in the kind of structured fee-setting approach discussed
earlier, the information needed to set appropriate fees would be most fully available
to management, and not the advisory councils. ASDB should modify its policy to
remove the provision that advisory councils will recommend a membership fee
structure.
Additionally, ASDB should determine whether to continue with advisory councils for
each regional cooperative or if it would be more appropriate to establish a single
advisory council for all of the regional cooperatives. There is no statutory or regulatory
requirement for the regional cooperatives to have advisory councils. Instead, the
advisory councils have evolved over time from earlier requirements outlined in the
regional cooperative pilot program legislation, which is no longer in place. Specifically,
when the regional cooperative pilot program was introduced in 1987, legislation
required ASDB to establish an advisory committee for each cooperative to provide
advice on the administration of the cooperative. The advisory committee included
parents, representatives from local private organizations that provide services to the
sensory impaired, and representatives of participating school districts. Current
regional advisory councils do not include parents or representatives of local private
service organizations.
The administrative duties outlined in ASDB policy regarding advisory councils could
be addressed by a state-wide council that includes representatives of participating
districts throughout the State and could also include parents and representatives of
private service organizations. Alternatively, ASDB could consider retaining the
regional advisory councils but include parents and service organization representatives,
similar to the way the councils were envisioned in the pilot program legislation. ASDB
should determine and implement the appropriate structure for the advisory councils.
Regardless of how the advisory councils are structured, ASDB management needs
ASDB should determine
whether to continue with
advisory councils for each
regional cooperative or if it
would be more appropriate
to establish a single
advisory council for all of
the regional cooperatives.
page 37
Office of the Auditor General
to provide oversight to ensure council authority in practice does not exceed the
advisory role outlined in ASDB policy.
Regional cooperatives are not consistent in tracking
resources
Regional cooperatives do not use the same systems to track resources, meaning that
students potentially may not receive the resources they need. Specifically:
• Education staff services—The regional cooperatives use different systems to
keep track of student needs, such as the need for an educational interpreter, and
the availability of educational staff such as interpreters, teachers, and therapists.
Each regional cooperative uses either a computer program such as Microsoft
Access or hard copy forms to manage its student caseload.
• Equipment inventory—The regional cooperatives use different systems to track
and manage the educational equipment provided to the students in local school
districts, such as braille writers and educational books. Some regional cooperatives
use a hard copy inventory tracking system, and others do not use an inventory
tracking system at all. Additionally, ASDB lacks a state-wide inventory system to
track equipment owned by all of its regional cooperatives.
Consistent tracking could help ensure that students have access to all the educational
services and equipment they need. For example:
• Providing resources when students move across cooperatives—Regional
cooperative officials reported that students move from one cooperative to another,
and because the regional cooperatives do not use the same computer programs
to track educational services, it can be hard to transfer the services to the
student’s new school.
• Identifying underused resources—Because there is no state-wide inventory of
equipment resources, some regional cooperative officials reported that they
informally call one another if they need equipment that might not be in use by
another regional cooperative. Without a state-wide inventory, equipment could be
going unused in one region that could benefit students in other regions.
• Training staff—Regional cooperative officials also stated that a single computer
program used by all regional cooperatives would make it easier to train staff and
IT support staff on how to use the program to track these services.
ASDB could use systems it has developed or is developing for other programs to
better track and manage educational services and equipment in the regional
cooperatives. Specifically:
ASDB lacks a state-wide
inventory system to track
equipment owned by all of
its regional cooperatives.
page 38
State of Arizona
• ASDB is developing an in-house computer program to track and manage the
schedules of the education services in the birth to 3 program discussed in
Finding 1 (see pages 9 though 25). This program administers these services
throughout the State. Once developed and tested, the regional cooperatives
should use this program to track and manage the educational services that are
provided to students by the regional cooperatives.
• As of January 2012, ASDB purchased and implemented an inventory system to
track on-campus assets. The regional cooperatives should use this same
system to track and manage the inventory of the equipment provided to the
students in the regional cooperatives.
Recommendations:
2.1 To ensure its fees more fully reflect its costs, ASDB should develop a structured
approach to evaluate current fees and implement new fees that would cover all
costs related to the services provided by the regional cooperatives that are not
covered by legislative appropriations, and ensure that specific fees are
appropriate for the services. In developing this approach, ASDB should do the
following:
a. Assess the efficiency of its operations to ensure costs are as low as
possible and document the results of its assessment. As ASDB assesses
the efficiency of its operations, it should continue seeking to minimize
costs where possible;
b. Determine whether to consider costs independently for each regional
cooperative or in combination on a state-wide basis, and develop and
implement a method for tracking and allocating relevant ASDB costs;
c. Identify the actual costs for specific fees, including membership fees, fee-for-
service costs, and additional supplemental service costs to help
ensure fees are appropriate and equitable. In addition, fees should take
into account factors that affect the cost of the specific service; and
d. Develop and implement policies and procedures for using the method to
develop appropriate fees.
2.2 ASDB should develop a systematic way to determine whether and how much
to pay school districts for services the districts provide to students for whom
ASDB receives Arizona Department of Education voucher monies.
page 39
Office of the Auditor General
2.3 ASDB should provide more oversight to ensure that advisory councils play an
appropriate role in the regional cooperative program by:
a. Modifying its policy to remove the provision that advisory councils will
recommend a fee structure;
b. Determining and implementing the appropriate structure for the advisory
councils, such as a single state-wide advisory council composed of
participating school district representatives and parents and representatives
of local private service organizations, or regional advisory councils that
include parents and local private service organization representatives; and
c. Ensuring that its councils adhere to the advisory role and responsibilities
outlined in ASDB policy.
2.4 ASDB should establish a single, consistent system for managing and tracking
regional cooperative resources by:
a. Expanding the use of ASDB’s in-house computer program for tracking and
managing birth to 3 program educational services, once the program has
been developed and tested, to track and manage educational services
provided to students in the regional cooperatives; and
b. Using ASDB’s inventory system for on-campus assets to track and manage
the inventory of equipment provided to students in the regional cooperatives.
page 40
State of Arizona
ASDB needs to improve its information
technology practices
FINDING 3
page 41
IT systems used extensively and contain sensitive
data
ASDB uses IT systems extensively. In addition to administrative functions such
as payroll and accounting, ASDB’s IT systems track and monitor student
information, including personal and medical information regarding students’
hearing or vision impairments and other disabilities, as well as information
about their educational performance. This type of information is private, and
two federal laws—the Health Insurance Portability and Accountability Act
(HIPAA) and the Family Educational Rights and Privacy Act (FERPA)—require
that such information be protected against unauthorized disclosure. ASDB
also uses IT in the classroom as part of a variety of adaptive teaching and
learning techniques for its students with hearing and vision impairments.
ASDB’s IT department, which consists of nine full-time employees, supports
technology for staff and students across its three campuses and five regional
cooperatives. This support includes administering and supporting user
workstations, servers, assistive and educational technologies, critical business
applications and services, and various other network devices.
ASDB has not addressed critical IT weaknesses
State information security experts and auditors have identified critical
weaknesses in ASDB’s IT environment. These weaknesses have persisted for
several years. In 2009, ASDB engaged ADOA’s Information Security group to
assess ASDB’s information technology environment. The resulting report
identified several gaps between the existing state of ASDB’s IT environment
and best practices and made recommendations for how ASDB should
address the deficiencies. The report also found that ASDB’s IT department had
received little strategic direction or oversight from ASDB management.
Although ASDB has made some efforts to address the weaknesses ADOA
identified, auditors found that critical IT weaknesses still exist. Specifically,
auditors found that ASDB’s IT security controls are weak, its disaster recovery
planning is inadequate, its data backup strategy is flawed, and it has no data
classification process to help ensure that the information it maintains is
sufficiently protected. ASDB officials stated that the IT department lacks the
Although the Arizona State
Schools for the Deaf and
the Blind (ASDB) has made
some improvements to its
information technology (IT)
practices since the Arizona
Department of
Administration (ADOA)
assessed those practices
in 2009, several additional
improvements are needed
to help ensure that student
and school information is
properly safeguarded.
Specifically, auditors found
that continued weaknesses
have led to critical
vulnerabilities in several IT
areas. These include IT
security management,
disaster recovery, and data
backup. ASDB should first
prioritize and then correct
these IT weaknesses to
minimize the impact these
vulnerabilities and security
threats could have on its
operations.
Office of the Auditor General
page 42
State of Arizona
staff and resources necessary to address all of ASDB’s IT issues and needs. As a
consequence, it has not prioritized addressing the recommendations made in
ADOA’s report, which has contributed to the lack of progress in addressing and
resolving weaknesses. In October 2011, the department had turnover in a key
position when ASDB’s IT Director left. At that time, the existing IT security specialist
was made the interim IT Director but also retained his responsibilities for security. As
of June 2012, ASDB had still not appointed a permanent IT Director.
IT security controls are weak—ASDB’s controls over IT security are weak, and
its systems are susceptible to attack. According to IT standards and best practices,
effective security management helps protect IT assets and minimizes the impact
that security vulnerabilities and incidents could have on IT operations. Security
monitoring is also essential to help ASDB comply with federal laws and regulations
designed to protect sensitive information, financial aid records, and health
information. Despite the critical importance of effective IT security management,
auditors found weaknesses in several key areas, including ASDB’s efforts to
assess risk and monitor its systems, secure its net